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Hi Dvd riley, have you sent out any cpr requests, here is a copy of a cpr18. what stage are you at now?

Karenza

Here is a cpr18

CPR 18 - REQUEST FOR INFORMATION

Dear Sir or Madam

 

I have received a recent court claim from your organisation. In order to file a defence and counter claim I require some information. Given that this matter is now the subject of legal proceedings, you are obliged to disclose under the Civil Procedure Rules, the information and documents detailed below.

 

The information must be furnished within fourteen days of the receipt of this letter. If you fail to comply, this will be reported to the Court, a copy of this letter will be provided as evidence to the same and an Order enforcing your compliance will be sought.

 

1. A true copy of the executed credit agreement and any terms and conditions that applied to the account at the time of default and at the time the account was opened. True copies of any notice of assignment and default notice or enforcement notice that you or the original creditor sent me, with a copy of any proof of postage that you hold.

 

 

1.1 If copies of any of the above documents are to be relied on in court rather than originals, a copy of the Notice of proposal to adduce hearsay evidence required under s2(1) of the Civil Evidence Act 1995 together with proof of the authenticity of the document(s) as required under s8(1)(b) of the Act, including but not limited to:

 

(a) a copy of the procedure(s) used for copying, storing and retrieving documents

(b) a copy of the relevant log entry showing the time and date of the scan or copy, the name of the member of staff making the copy, the method used for copying, storage and retrieval and time and date of destruction of the original document(s)

© copies of internal and external audit reports covering the entire period from the date of the copy to the present to demonstrate that the procedures have been complied with

(d) copies of Quality Assurance accreditation certificates covering the entire period from the date of the copy to the present to demonstrate that the procedure(s) and audit process(es) comply with the appropriate quality standards

 

2. All records you hold on me relevant to this case, including but not limited to:

 

a. Where there has been any event in my account history over this period which has required manual intervention by any person, I require disclosure of any indication or notes which have either caused or resulted in that manual intervention, or other evidence of that manual intervention in relation to my account formerly held with *********.(AMEND TO THE COMPANY NAME)

b. .Documents relating to any insurance added to the account, including the insurance contract and terms and conditions, date it was added and deleted (if applicable).

c. Details of any collection charge added to the account; specifically, the date it was levied, the amount of the charge, a detailed financial breakdown of how the charge was calculated, and what the charge covers.

d. Specific details of the fees/charges levied by any other agency in respect of this account and a detailed breakdown of said fees/charges and what each charge relates to and on what date said fees/charges were levied.

e. Copies of statements for the entire duration of the credit agreement.

f. The Deed of Assignment

g. Evidence of securitisation in the UK

h. The termination

 

 

3. Any other documents you seek to rely on in court.

 

 

I will require this information within the next fourteen days. I must advise you that if the information is not forthcoming, it will be reported to the Court that you are trying to frustrate proceedings and denying me the opportunity to file a defence and counter claim.

 

Yours sincerely,

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Guest dvdriley

I have received received their disclosure list with copy agreement , dn and noa.

 

but i dont know how to sent my list to them, do i send them docs,? i need more info from them. Getting stuck now

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Guest dvdriley

aq been done and hearing completed. Fast track. i have not received the full order as courts are too busy! i know standard disclosure list must be by 24/8. i have been doing so well but am now stuck here.

 

I have an ace up my sleeve by way of a wintness stament , do i disclose this now

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Hi dvdriley,

I am no expert, like you i am going through the process and we seem to be at much the same stage. I can tell you that you must make sure your disclosure by list in in on time and file a copy to the court.

There is a form you can print of the net N265 which you need to fill in. You will need to list all correspondence you have, both received from and sent to the claimant and any case law you wish to refer to if you get to a hearing, you may need to list this seperatly and attached to the form as for the your other question i can't answer this hopefully someone else will come along who knows the answer, i am also asking for advice regarding inspection of documents but struggling to get any help have you seen my thread?. Cabot /morgan solicitors advice needed disclosure by list

karenza

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