Case Management Conference 13th Oct. 06

[Its WAR]

RESULT........ I had four claims being heard at this conference. HFC and two Black Horse claims have now refused to attend and settled instead. Leaving NatWest as my last remaining claim (for this set of hearings). They have already made a part payment of £1800 and we now still arguing a further £3000.

 

So now Natwest will suffer all the extra costs instead of it being split between 4 claims. I bet Natwest will attend just to put off the bitter day when they get to issue the cheque. This is an abuse of the system and the many times this has happened must be brought to the attention of the QC at the Conference...Its WAR.

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Today I received a schedule of costs from Cobbetts. They will be seeking £1147 in solicitor charges which will include Counsel's fee of £750 for attending the Case Management Conference. The fee earner is on £95 per hour and the trainee is £75.00. Now, I wonder how many other claimants will be at the conference and whether they have all had their version of a schedule and whether this fee should be split 10 ways for instance. Or if ten cases, whether Cobbetts council are thinking they can come away with £7500. I gather the £750 fee is the max allowed by a Mercantile Court, but this isnt a Mercantile Court, its just a CMC to decide whether a Mercantile or County Court will hear the case. Anyway, costs will be awarded against the loser at a full hearing, and no costs at all at County Court level.

 

Its almost offensive to have this sabre rattling at the death. A couple of more blows and it should all be over. Martyn Lewis has well and truly sealed the banks fate today. County Courts will have to start recruiting.

 

Now the secret.......

 

Yes, Natwest, be the first bank to offer full repayments to all customers past and present. It will cost millions in repayments. But think of the advertising that will earn you. If you plan to do it (on the back of an acknowledgement of what turned into bad paractice) and you get all your competitors disgruntled customers coming to you. All you need to do is offer the right product and make these swift payments part of the deal. No fancy 0% interest on balance transfers or flashy shaped plastic. Save the money you are wasting on Cobbetts and the milllions they will earn from you next year. Just acknowledge the unlawfull activities, hands up, put things right and let your competitors fight tooth and claw amongst themselves and their ex customers who have come back to the first bank (Natwest ?) that understands. Someday all banks will be this way....no rewards for second place.

[Its WAR]

Case Management Conference is over. Where on earth do I start. I'm sure you all want to know the ending, sooooo, I'll start at the beginning. The CMC was to hear directions for 4 cases I had brought along with a bunch of other cases brought by others. 3 of my cases were settled before the conference so I only expected to be up against NatWest. I expected to meet a bunch of other claimants up against them too, and maybe a few other banks. How wrong I was. It appears every case had previously settled. Except my Natwest case. So it was me and Natwest....thats it. The CMC was heard by His Honour Judge Havelock-Allen QC. Of course before he could give directions, he had to hear Cobbetts barister (who travelled down from Manchester) give his presentation as to why the judge should strike out my claim. Thus commenced a two and a half hour war of words. While the barister argued that my "claim did not disclose any legally recognisable claim" and "had no real prospect of success" and "no compelling reason it should be disposed of at trial". He was relying on Cobbets witness statement (Lynsey Burgoynes) as evidence to support his application to strike. Now, my case may differ to any readers, in that I had already accepted as part payment an amount from cobbetts £1800, equal to the charges, plus court fees with 8% section 69 calculated on the charges. So the CMC only related to strike out the interest Natwest had charged on the unfair charges part of my claim and sec 69 8% on that portion only. The only part of Cobbets witness statement concerning this was "I respectfully submit that the claimant has no real prospect of succeeding on the remaining issue in dispute in relation to interest at 23%. The claimant is not legally entitled to claim two sets of interest, as effectively the claimant would be making a double recovery".

 

This interest claim valued £2200 plus section 69 £1200 Total £3400. So it was a big deal. The barister started to suggest that section 69 8% was not applicable because it was already calculated within the 23% I was claiming. This point was won by my reply. Basically argueing that if the bank charges and interest were valid claims then section 69 8% is the recognised standard allowed by the court. That although the 8% is a discretionary award, whether it is awarded comes after judgement. It would therefore be wrong to strike out a claim on the suggestion that it would be a double recovery, that question could not be argued until/unless judgement on the claim occurs first. Therefore not a valid reason to strike.

 

The barister then moved on to the point that the 23% was a flawed calculation, innacurate and had no merit. The judge argued that if the bank charges were valid (and the bank had already refunded them) then interest on those charges must also be a valid argument and in fact had a reasonable chance of success if it were allowed to be argued in a hearing. (things were going my way....the judge was pleading my case for me). Then the bombshell. While I was being charged 16.9% on my charges and at times 29.5% on the unauthorised part, I had arbitrarily averaged them to 23%. The judge suggested that this sum was certainly not likely to be the exact sum, especially if the 29.5% was only charged some of the time and the 16.9% most of the time. The 23% would be less and could be much nearer to the 16.9%. Because I was unable to provide specific amounts, I could easily be over valueing the interest (I could also be undervalueing it) One thing was certain, an average was probably not accurate enough to convince him the amount claimed was accurate. I argued back with purpose and passion, that the 23% was based on a mathmatical formula that although not neccesssarily precise was at least a fair attempt at compromise. I drew his attention to correspondence between me and cobbetts, where I suggested if they were unable to agree that the amount I was claiming in interest was innacurate, I would welcome their input to arrive at a more accurate method of calcualtion and I would therefore amend my claim.Then the next volley of bombshells....The judge said Natwest were under no obligation to tell me the amount they had charged me in interest (even if all they had to do was press a button on a computer to get the figure). I had brought the claim, it was for me to have accurate evidence to support my claim. I therefore had to explain how I arrived (not just at 23%) but the amount it came to. I suggested that I had used google to calculate compound interest at a daily rate to give me the answer. This raised two points, was compound the correct method (I dont know) so I said yes and explained why. Then, was daily interest and not quarterly or annually right. I explained why it was (but I dont know for sure). Then, the explosive nuclear bombshell. The barister had another go. He started adding to Lyndseys witness statement. And this is the important issue which caught me totally unprepared.

 

The interest I was claiming is not just arguable over the value (maybe 16.5, maybe 23, maybe 29%) but whether it was payable at all. It seems that although the interest is clearly and demonstrably charged to me, that didnt mean that I had actually suffered that sum as a loss. It was just an entry on a statement and I didnt actually suffer a financial loss until I made an attempt to pay off the interest. Until then I wasnt out of pocket. Inother words if the debt was running for 6years and interest kept acrueing, I would only be out of pocket when I paid the debt off. That paying off date could have been last week and therefore I could claim an amount x 6 days interest not an amount x 2000 days. Therefore my calculation should be based upon the days from my payments not from the days the interest was applied, and that indeed there was no loss at all for any days my account were in credit. My calculations missed these points entirely and should therefore be struck out. They were a mere guess at what may or may not be reclaimable and I had no evidence to support my claim, other than an average.

 

The judge said he didnt know what a google compound interest calculater was and this cast doubts as to how I had arrived at and claimed the 8% sec 69 on top of what could be wildly innacurate interest claims. I advised him that I used the courts own recomended 000.21 x £??? x days. He hadnt come across that equation either..........MY heart sank, I was stuffed. But I bet he will look it up later.

 

So to the summing up. I spoke up the best I could, the barister had one more go. The judge gave his response bit by bit. On point one, he couldnt allow the strike out, nor on point two as no legal reasons were given to support why he should. As for the interest, he suggested that the principle of whether the interest was reclaimable from date it hit my statement, or from the date I paid it, could make a huge difference to the value of the claims, but in itself was a perfectly arguable position and could be judged one way or another supported by inteligent and accurate figures. Therefore the claim would be allowed to proceed in order that these points could be argued. It then took five minutes to decide that a county court judge back in Taunton could hear that case and he would return the case accordingly. In the meantime, I was advised to be prepared to argue why interest should be claimed from date it is applied to my account rather than the date I suffered the actuall loss incurred by paying it and to be more accurate than averaging it. I believe he was not ready to strike out at that time because that meant he would effectively be judging which methods were the correct way to apply interest. He recognised that I could therefore arrive at a different (lower?) sum and NatWest and I would probably end up negotiating a settlement. He gave me the window to do just that, or have another day in court.

 

So thats that. Happy to answer questions, but no more tonight, I feel brain dead, bruised and battered............Oh nearly forgot......Halifax letter today £1080 credited to my account and £365 to another. Happy days............

 

I have copied his entry to my Natwest thread £10,000 v Natwest.

[Its WAR]

It was not contractual interest. Funny though, the barister suggested that it could have been and his argument would not have been so effective. I supported that view of reciprocity to the judge and he just smiled to himself as though that was a very weak idea.

 

Anyway, I still have the case to settle and my other remaining natwest claim. So its back to the drawing board trying to figure out a more accurate way to calculate interest. And get the words together to argue whatever position I take. Not to convince a judge but to get a water tight arguement to enforce settlement prior to a hearing. I think we can be sure the banks wont tell us the figure, but they will probably keep making offers.

[Its WAR]

I cant remember where I read: It was in one of the Acts, Sale of goods, Unfair terms or similar: That if a contract were ambiguous, then it should be decided in favour of the consumer. Therefore, if the banks T&Cs do not prescribe what debts get paid off first, or in what order, then it would suggest that the consumer could argue any order that seemed most suited to the claim. However, we still have to find the argument that supports our point that we should be claiming interset from the date it is recorded on our statement and not as the banks suggest, that we have not incurred a loss until we have actually paid it (which suggests that the interest and charges are not a loss until the final amounts of the overdraft equal the combined charges and interest. Only then do we ommence a loss). However, I would argue that the interest becomes due on demand and if correctly allocated to the account (rather than illegally) that would be once it hit the statement. Secondly, any money paid in would be first applied to the most historical part of the debt, therefore paying off a portion of overdraft, interest and charges, followed by the next portion of overdraft, interest and charges. Therefore the banks argument that the interest was last to be paid off and therefore any illegal loss to us would be far shorter or not at all, could be flawed. However, its still up to us to arrive at both the argument and the calculations.If the banks offer to settle the charges (whether we accept the part payment or not), they can proceed to any hearing and rely on us to prove our figures to support our claims for the interest portion. They will argue their best, causing doubt and confusion. The judge may not be mathematically articulate and therefore our argument must be capable of persuasion, simpicity in its explaination and convincing in our presentation of the maths. As long as we are able to explain our numbers more clearly than the solicitor in trying to poo poo them, we can win the case. So whats the argument and whats the formula....................?

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..

[Its WAR]

OK Found it......... 7(2). Therefore any reference in the T&Cs which relate to repayment of overdrafts, charges & interest (illegal charges & interest) would make the term unfair if the contract forces us to repay an illegal charge. If there are doubts as to what order our payments go towards clearing the illegal charges, these doubts would be interpreted to our benefit.

 

Unfair Terms

5. - (1) A contractual term which has not been individually negotiated shall be regarded as unfair if, contrary to the requirement of good faith, it causes a significant imbalance in the parties' rights and obligations arising under the contract, to the detriment of the consumer.

 

(2) A term shall always be regarded as not having been individually negotiated where it has been drafted in advance and the consumer has therefore not been able to influence the substance of the term.

 

(3) Notwithstanding that a specific term or certain aspects of it in a contract has been individually negotiated, these Regulations shall apply to the rest of a contract if an overall assessment of it indicates that it is a pre-formulated standard contract.

 

(4) It shall be for any seller or supplier who claims that a term was individually negotiated to show that it was.

 

(5) Schedule 2 to these Regulations contains an indicative and non-exhaustive list of the terms which may be regarded as unfair.

 

Assessment of unfair terms

6. - (1) Without prejudice to regulation 12, the unfairness of a contractual term shall be assessed, taking into account the nature of the goods or services for which the contract was concluded and by referring, at the time of conclusion of the contract, to all the circumstances attending the conclusion of the contract and to all the other terms of the contract or of another contract on which it is dependent.

 

(2) In so far as it is in plain intelligible language, the assessment of fairness of a term shall not relate-

 

 

(a) to the definition of the main subject matter of the contract, or
 
(b) to the adequacy of the price or remuneration, as against the goods or services supplied in exchange.
 

Written contracts

7. - (1) A seller or supplier shall ensure that any written term of a contract is expressed in plain, intelligible language.

 

(2) If there is doubt about the meaning of a written term, the interpretation which is most favourable to the consumer shall prevail but this rule shall not apply in proceedings brought under regulation 12.

 

Effect of unfair term

8. - (1) An unfair term in a contract concluded with a consumer by a seller or supplier shall not be binding on the consumer.

 

(2) The contract shall continue to bind the parties if it is capable of continuing in existence without the unfair term.

[Its WAR]

Yes, but where from?

[Its WAR]

Thats great. The argument is well worth developing. Can it be supported by quoting various Act references?

[Its WAR]

Lets get back to business. CMC ORDER has now arrived. I have already recovered the bank charges back and the CMC has therefore: 1) struck out that portion of my claim. 2) NatWests application to strike out the balance is refused. 3) The CMC has allowed the claim to continue in respect to the interest and section 69 interest. 4) I have permission to revise and or further particularise the schedule of interest and can reserve docs to NatWest. 5) Natwest can serve an amended defence. 6) The claim is transferred back to Taunton.

 

This means I can raise fresh argument to support my claim for interest and could even approach the interest from a different angle. So its back to the drawing board to recalculate and introduce a whole set of new arguments.

 

Also, my other Natwest claim is returned to Taunton too. (I had accepted a part payment subject to the case continuing but Natwest have not sent the cheque). It will be interesting to see which case gets the sooner hearing date.

[Its WAR]

This was the bundle pre Case Management Conference.

 

 

Cobbetts Llp

Ship Canal House

King Street

Manchester

M2 4WB

 

Dear Sir,

Please find enclosed documents prior to the Case Management Conference 2pm 13th October 2006.

Copies have been sent to the Court.

1. Claimants further reply to your CPR part 18

2. Claimants reply to your Defence.

3. Witness statement of Claimant

4. Case Management Information Street

Yours faithfully

 

Bristol County Court

 

Before His Honour Judge Havelock-Allan QC

 

Between

 

 

and

 

Case no xxxxxxxxx

 

 

 

REPLY TO THE DEFENDANTS DEFENCE

 

1. The defence is a template and identical (word for word) to defences provided against many similar claims brought against the Defendant nationwide. Including the same typographical errors.

 

2. In reply to point 3. The Defendant has been provided with this schedule. And the Claimant would seek reciprocal full details with all supporting documentation of each and every breach by the Claimant which resulted in a charge being levied as confirmed by the Defendant in its Defence.

3. In reply to point 4.1.

a) The Defendant appears to be requesting the Claimant to identify where the

Claimant has breached the contract. The Contract and published Terms and

Conditions are quite clear regarding the breaches.

b)The Claimant would ask how charges are applied to the account (whether

automatically or by some other means) and when.

c) Further, the Defendants assessment of the cost to it of sending any letter

making any telephone calls or otherwise administering the account, with details

of how the cost to the Defendant is calculated and what items of expense are

included, or such other costs as are foreseeable in the context of contractual

damages and the remoteness thereof and which can be specifically identified and

defined and which can be reasonably attributed to each and every breach on the

part of the Claimant.

d)The justifiably objective principles upon which all such costs are calculated and

result in the specific level of each charge levied by the bank in respect of each of

the breaches which resulted in the charges now claimed by the Claimant.

 

4. In reply to point 5.1 – 5.3.4. The Defendant is well aware of the contractual

provisions. The Defendant wrote them. Solicitors representing the Defendants are

very familiar with the quoted Acts and do not require the Claimant to be more

specific at this stage.

 

5. In reply to point 5.3.5 Where the Defendant avers that the charges are applied

in return for the provision of a banking service to the Claimant: The Claimant

would ask that the Defendant identify each and every such service referred to

in the defendants terms and conditions and identify the charges, by reference to

those terms and conditions, that the Claimant is required to pay for each

service identified.

 

Further, to confirm what steps are taken by the defendant in providing the

alleged services referred to in the defence and to provide copies of all notes,

memoranda, or other information retained by the defendant to demonstrate the

provision of the alleged services to the Claimant. To also confirm whether the

charges are applied automatically.

 

6. In reply to point 5.4.2 – 5.4.5 Above replies apply.

7. In reply to point 6. The Defendants are aware that Part 18 does not apply to Small

Claims Track. The Claimant considers that upon allocation this claim being less than

£5,000 will be so allocated. The Claimants consider this request to be intimidatory as

Part 18 is excluded. The Request was made early in the proceedings and designed to

cause certain Claimants to worry, possibly withdrawing their claims due to escalating

difficulty and mis-understanding of terminology and process. This tactic is offensive

and tantamount to an abuse of the system of the court. However, the Claimant has

considered further his reply and the responses have been made to the Defendants

CPR part 18. The Claimant asks the Court to order the Defendant to reply to

reciprocal requests for further information.

 

8. In reply to point 7. The Defendants have received many similar claims nationwide. It

is quite wrong of them to suggest they do not understand exactly the whole purpose

and scope of these claims notwithstanding any errors of terminology or lack of

particularisation.

 

The Claimant believes the facts in this reply to the Defence are true.

 

Signed

Dated

 

 

 

Bristol County Court

 

Before His Honour Judge Havelock-Allan QC

 

Between

 

 

and

 

 

 

 

 

WITNESS STATEMENT OF CLAIMANT

 

1. I am xxxxxxxx and am acting as Claimant in Person

 

2. This witness statement is made in support of my claim and in reply to the Defendants (undated and unsealed) application for an order to strike out and Summary Judgement against the remainder of my claim.

 

3. The Defendants (along with many other banks) have experienced an increase in similar claims for repayment of unfair bank charges. Using a variety of legal process to argue and delay and complicate their defence. Whilst the Defendant argues these claims all fail to disclose a recognisable claim and none have any chance of succeeding and therefore should not proceed to a hearing: The Defendants refuse to attend any hearing and in all cases have negotiated settlements prior to hearing rather than attending a hearing.

4. The Defendants behaviour effectively thwarts the Courts from being able to make a judgement.

5. Whilst I am acting as Claimant in Person and cannot afford representation but wish to mitigate any escalation in cost bearing activity. It is seen that the Defendants are quite prepared to continue with cost bearing activity without any prospect or inclination to allow any Claimant the justice of a hearing and associated judgement.

 

6. The Defendants solicitors application represents their efforts to have the case struck out rather than heard and effectively they “win” on behalf of the Defendant upon successful application without the risk of a hearing or judgement against them.

 

7. Whilst the Defendants have made a payment accepted as a part payment on the understanding that the claim proceeds for the balance, the Defendant is now attempting to ensure the claim progresses no further. The part payment was accepted on the understanding that the case would proceed or settle in full, not struck out.

8. In reply to the Defendants point B3. The Claimants Amended Particulars of Claim sealed by the Taunton County Court are not the draft amended particulars the Defendant has attached to their Application to strike out.

 

9. In reply to the Defendants point B4. The claims referring to the Limitation Act are flawed in that the amounts are fairly claimed and but for the Defendants failure to comply within the time provided, to provide statements from which charges could be confirmed, would have fallen inside the 6 years required of the Limitation Act.

 

10. In reply to the Defendants point B5. The claim is asking for the return of the charges plus the interest the Defendant has levied on those charges to arrive at the total claim plus costs. Section 69 allows Claimants to apply a further 8% per annum. If the Defendant believes the calculation of interest is incorrect, the Claimant requires (and has previously requested) the Defendant to prove a more accurate calculation rather than provide a simple list of figures. The Defendant has failed to comply.

11. In reply to the Defendants point C7. I would suggest that the most compelling reason to proceed to trial is in order that a judgement can be made based upon evidence provided by both parties. If the Defendant is so confident of their position (that the Claimants have no prospect of success) they should be capable of defending such a claim without fear of the wrong outcome.

12. In reply to the Defendants point C9. The Defendants charged the Claimants between 16.5% and 29.5% interest on top of the illegal bank charges. The Defendant refuses to confirm their calculation of this sum and the Claimant has therefore claimed an average of 23% in the lack of any other evidence or calculation indicating a more accurate formula. There is no double recovery.

13. I ask the Court to allow this case to a full hearing and judgement. If the Defendant

remains unsure of their prospects of success, a hearing date will focus their

attention to settle rather than escalate delay and further frustrate these claims by

taking advantage of procedures which might otherwise cause another claimant in

person to lose heart and withdraw. It appears this is the strategy the Defendant is

using against many ordinary and unrepresented people nationwide.

 

The Claimant believes the facts in this statement are true.

 

 

Signed

 

 

Dated

 

 

Bristol County Court

 

Case Management Information Sheet

 

Before His Honour Judge Havelock-Allan QC

 

 

 

 

 

 

Part Filing: Claimants

Solicitors Acting: Claimants in Person

Date

 

 

Substance of case.

1. The Claimant seeks repayment of unfair & unlawful bank charges and interest.

Parties

2. Yes

3. No, although Taunton County Court may link other claims.

Statements of Case

4. No

5. Yes. We believe CPR 18 may only become necessary if the Court directs other than to a Small Claim. However, the Defendant has insisted the Claimant complies with the Defendants CPR Part 18, the Claimant therefore seeks the Court to order full disclosure and breakdown of the administrative cost incurred in applying the said charges.

Disclosure

6. Within 7 days of being requested by the Court.

7. No

8. Yes: List of charges made to claimants accounts and in respect of every charge, a breakdown specifying the amount of actual cost to the defendant and the amount of profit added, resulting in the total charge made to the claimant in each and every charge.

9. Yes:

10. (i) Within 7 days of Courts directions

(ii) Within 7 days of Courts directions

Admissions

11. No

Preliminary issues

12. No

 

Witnesses of fact

13. One

14. Claimant

15. Claimant

16. Within 7 days of Courts directions

17. No

 

Expert Evidence

18. No

19. No

20. No

21. None

22. N/A

23. No

24. None

25. N/A

Trial

26. 1 hour

27. Within 4 weeks of Case Management Conference

28. Bristol County Court

29. No

A.D.R.

30. No

31. No. The banks have so far refused to attend hearings being content to take

the full period of the process before settling at the last minute.

32.No

33.No

Other applications

34 None.

 

Costs

35. Claimant in Person costs £9.25 per hour 18 hours research & preparation £166.50

plus £16.00 sundries expense.

36. Attendance in Bristol for Case Management and subsequent hearing total 200 miles

at standard mileage and car park rate. Further costs say 4 hours at hearings plus 4

hours travelling. Plus 10 hours additional research and preparation. Plus £4.00

sundry expense.

 

 

 

Signed Claimant

 

 

 

 

 

 

 

In the Bristol County Court

 

Before His Honour Judge Havelock-Allan QC

 

Between

 

 

and

 

 

 

Claim Number xxxxxxxx

 

 

 

 

1. This response is served pursuant to the Defendants CPR 18 REQUEST of 17 July 2006

 

2. In response to Para 2.1 of the defendants request the Defendant received this information with the Amended Particulars of claim on or around 1st August 20061.

 

3. In response to Para 2.2 of the defendants request, the claimant has already explained why the charges should not have been applied but for the avoidance of doubt the claimant alleges that the charges are Penalty charges and are irrecoverable at common law. The precedent for this was Dunlop Pneumatic Tyre Co Ltd v New Garage and Motor co Ltd [1915] AC 79.along with Murray v. Leisure play [2005] EWCA Civ 963 It was held that a contractual party can only recover damages for an actual loss or liquidated losses Further or in the alternative the charges are contrary to the Unfair Terms in Consumer Regulations 1999.

 

Para 2.(a) The claimant should not have been charged an amount above the true administrate cost incurred by the defendant, (b) the claimant should not have been charged for reason out lined in Para 3. © the claimant should have been charged the true administrative cost.

 

4. In response to Para 2.2(d) The Defendants have asked what the claimant should have been charged, to answer this the claimant will need a break down of the administrative cost incurred by the defendant in applying the said charges.

5. In response to Para 4. If the defendant is trying to say that the charges are for a service then the clamant will argue that the defendant has attempted to restructure accounts in order to present events of default spuriously as additional services. The UTCCRs are concerned with the intention and effects of terms, not just their mechanism. For example, a charge for 'agreeing to' or 'allowing' a customer to exceed his credit limit is no different from a charge for the customer's 'default' in exceeding his credit limit.)

 

6. In response to the further questions made by the defendant the claimant will not be able to respond to these until the claimant has disclosure and inspection of documents as the claimant will be requiring a copy of his contract with the Defendants

 

7. If the defendant requires any further information, the claimant will be happy to provide this once the discloser of documents/information has been dealt with by the court.

 

 

The Claimant believes the facts in this statement are true.

 

 

Signed

Claimant

 

Dated

[Its WAR]

Gagging order Im afraid with Natwest. But I have 9 other cases to be heard in Taunton County Court on 12 Feb. (Actually only 7 now, two have paid up today). I need to prepare bundles and exchange them by 28 Jan. Complete waste of time if they pay up also, one by one, but is has to be done just in case I am the lucky one to actually have to battle it out in court.

 

So what goes in the Court bundles?

[Its WAR]

Court Bundles.........what a job that was........... 7 bundles prepared for 7 hearings to be heard 12th Feb. Monday 29th Jan is the deadline to exchange docs with banks and to give copy to court, plus retain my own copies. That makes 21 sets (each around 100 pages including statements). Interesting though, I havent received any defence bundles from the banks. I will apply to have judgement in default if any bank fails to deliver their bundles on Monday. So 14 days and counting......shame all the amounts are £500 and less. Its a lot of work but must see it through to the end.

[Its WAR]

Yes, keep a log of your hours.

Great idea about the lap top. I decided to cheat while printing off the docs, and have risked providing one set of docs to cover all cases to the court, rather than 7 sets virtually all duplicates of each other. Same to Barclays, (3 claims...1 set of docs). I have not printed my docs either. I am guessing the cases

[Its WAR]

Yes, keep a log of your hours.

Great idea about the lap top. I decided to cheat while printing off the docs, and have risked providing one set of docs to cover all cases to the court, rather than 7 sets virtually all duplicates of each other. Same to Barclays, (3 claims...1 set of docs). I have not printed my docs either. I am guessing the cases will all be settled prior to the hearings.

[Its WAR]

Halifax agreed to settle, thats two less cases for monday.