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    • Lining up my ducks and preparing my WS in advance. 1st draft below. Feedback appreciated. In the County Court at ************ Claim Number:***************** BETWEEN: Claimant: ********************** -and- Defendant: *********************** WITNESS STATEMENT OF ******************   I, *********, being the Defendant in this case, make this Witness Statement in support of my defence which is due to be heard on DATE at ************ County Court. I contest that the Claimant's claim is vague and unspecific. On DATE I made a written request to the Claimant requesting that the Claimant provides copies of all documents (true copy of the executed agreement and a copy of current terms and conditions encapsulating any variation) mentioned in the Statement of Case (Exhibit A). On DATE I made a written request to the Claimant Solicitors requesting that the Claimant provides copies of all documents (Credit Agreement, a copy of the Contractual payments under the terms of the agreement and the Default Notice) mentioned in the Statement of Case (Exhibit B). On DATE the Claimant’s Solicitors replied (Exhibit C) to my written request without the requested documents. On DATE the Claimant replied (Exhibit D) to my written request without the requested documents. The Claimants claim is based upon Defendants alleged breach of contract and therefore, the contract is entirely central to the Claimant’s case. CPR Rule 31.15 requires that documents are provided within 7 days from receipt of a written request. The Claimant has failed to provide any of the documents mentioned in its claim form. On DATE I contacted the Claimant and repeated my request for copies of documents as mentioned in the Statement of Case (Exhibit E). The Claimant has mentioned the Credit Agreement, the Default Notice and the Assignment in its Statement of Case and yet it has provided none of these documents despite my entitlement to inspect these documents or if they can provide originals for Court inspection. The claimant has provided a 'reconstituted' set of statements which are not original documents The Claimants pleaded case is that the Defendant entered into an agreement with ***************** under account reference ************, I am uncertain as to which account this refers to. It is accepted that I have had ****** Loans in the past, however, the account number given does not relate to any information I have, therefore, it is essential that I have sight of the agreement relied upon by the Claimant to be able to accurately identify to what the claim refers. I believe that the facts stated in this witness statement are true. I therefore ask that the Court orders the Claimant to provide copies of the documents and if the Claimant is unable to comply the proceedings are struck. Statement of Truth I ************, the Defendant believe the matters set out in this Witness Statement are within my own knowledge, except where I indicate to the contrary. Signed: ________________________________ Dated: ________________________________
    • Brilliant, that's reassuring.  Off to the Hermes forum now.
    • No, I think UK will get same deal as EU.  Main reasons for this are two sectors,  Defence and Financial Services.  US have huge levels of money invested in the UK, so they have a self interest in offering a trade deal as good as the EU.
    • @labrat I'll bet it isn't the subframe itself that's broken. It'll be the subframe mounting bolt(s) that have sheared off inside it. Because the bolt is seized inside the subframe, it effectively renders the subframe scrap. I suspect the garage are simply talking in terms the average customer is more likely to understand than going into the detail of it. The Golf, Jetta and Beetle, which are all mechanically identical, are notorious for it.    A smaller independent garage may have tried to get the bolts out, but you very quickly reach the point where time/effort/cost is simply not worth it and replacement of the whole subframe is the better choice.   Of course the OP could approach a salvage yard, either local or online, and ask about the cost of a good used item, which would be substantially less expensive than what I assume is the price VW are charging for a replacement.
    • Applied for and awarded by BY in Sept 2020 still not received it yet Comments appreciated
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    • Hi @BankFodder
      Sorry for only updating you now, but after your guidance with submitting the claim it was pretty straight forward and I didn't want to unnecessarily waste your time. Especially with this guide you wrote here, so many thanks for that
      So I issued the claim on day 15 and they requested more time to respond.
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    • Hermes and mediation hints. https://www.consumeractiongroup.co.uk/topic/428981-hermes-and-mediation-hints/&do=findComment&comment=5080003
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Porting issues - no mobile data for 6 WEEKS - 10170864 Vodafone customer service appaling

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Hi All,


First post on the forum, but have read many other similar threads now that I have done some searching on the internet - wish we had done so before switching to Vodafone.


Brief summary:

Vodafone seem to have messed up porting a number and while it can call and text the SIM can't get any mobile data at all. It's been like this for 6 weeks and Vodafone don't seem to be able/willing to do anything about it. Meanwhile they're still taking our money.


I've complained in store (more than once waited in the store while staff are on hold to someone else for so long that the store closes and I get kicked out!), I've spoken to them on the phone, and have spent hours on the webchat system, I've even made a complaint directly to the CEO.


Every time I complain I'm told just to wait 24/48/72 hours and the mistake will be corrected. It never is. From what I can gather only a handful of people in Vodafone can actually interact with the porting system and they are never customer facing and difficult for even executive level complaints to get in touch with.


I'm on here to see if anyone can give advice about what to try next? It seems like options might be:


  1. Complain to ombusdsman services - unfortunately they won't take the case on until 8 weeks have passed, so have to wait a little longer before approaching them.
  2. Try to tackle Vodafone legally as a breach of contract - they're more than happy to collect the direct debits but are not providing the service we agreed to - perhaps there is an appropriate angle here?
  3. Something else? Maybe the better informed users of this forum have good suggestions?


Looking forward to getting peoples thoughts - help!


Thanks for reading



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Hi and welcome to CAG


I have seen this a few times now where VF just can't seem to get their act together. Do they actually want your custom.(rhetorical question) I feel that they are getting so big that customer service has gone.


Anyway, we do have a rep here from VF who should be able to assist in what should have been a simple issue.


Follow this link




You will get back an automated reply number. Post that number on this thread so that the VF rep (usually Lee) can reconcile this thread with your email

If you are asked to deal with any matter via private message, PLEASE report it.

Everything I say is opinion only. If you are unsure on any comment made, you should see a qualified solicitor

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Hi Silverfox,


Thanks for the welcome, and for your assistance. I've done as you suggested and have gotten the automated response with the reference: WRT135 [#10170864]. Hopefully the rep here will be more successful in picking it up than my other numerous attempts to communicate with Vodafone.


Regards your sentiment I couldn't agree more. The problems Vodafone are having with porting (for about the last~6 months in particular) are all over the internet (not least on their own support forum) and all experiences from the public/customer point of view are that they simply do not care.


I do appreciate that systems in large companies don't always work like they should, but I have lost count of the number of times that Vodafone have told us that this will be fixed, only for the timescale promised to pass and no change to have been made. Their customer facing staff have lied directly to me on at least 4 occasions, which is completely unacceptable.


Anyway, hopefully someone out there who can help will find this and take action.


Thanks again,


Frustrated - Owen

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I have added the reference number to the title of this thread so it should be even easier for this to be seen.

If you are asked to deal with any matter via private message, PLEASE report it.

Everything I say is opinion only. If you are unsure on any comment made, you should see a qualified solicitor

Please help CAG. Order this ebook. Now available on Amazon. Please click HERE

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I just wanted to add that I am in the same position (although 'only' waiting for 10 days).


I'm currently dealing with the customer relations team who admittedly have refunded me the first month so at least I'm not paying for the service. Although I don't feel that's good enough as it's not just the lost service. I've spent over 8 hours contacting them and it's more than not having being provided with a service. I have no phone at all and cannot receive any calls whilst I'm searching for a job.


Goodluck Owen - If you do manage to get it sorted, keep in contact how as it might help. Similarly, I will keep you updated.

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Hi All,


Another small update. Made another call to customer relations today. Very polite but can't commit to any timescales on when they might get back to me with more information or when it might be fixed.


I have now gotten a reply from someone at Vodafone over on their own eForum, but only to say they will be in touch - again no context or timescales.


Will update when there is more info





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  • 2 weeks later...

Hi Matty,


No joy here yet.


We got an email from Chris Warder at Vodafone on Friday 1st May saying that the issue had "finally been fixed", we should re-start the handset and it would be ok. We did this several times but there's been no change. So far no response to our email of 6th May responding to tell them that the problem had not changed. I'm going to raise another 'Ask Jeroen' complaint today, as this seems the only way to guarantee a reply (within 48 hours).


Meantime we have also made some progress with Ombudsman services, they have taken on the case (reference 01111206-01 if anyone reading can access it) but have said that they will contact vodafone, who will then take 28 days(!) to respond, and that it could take a further 6 - 8 weeks (!!) for Ombudsman services to reach a conclusion. I think the best we can hope for is that it won't take this long.


Best of luck to you all who are in the same position.





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