Have not received any responses, so after a bit of research have come up with-
1. The Defendant contends that the particulars of claim are vague and generic in nature.
The Defendant accordingly sets out its case below and relies on CPR r 16.5 (3) in relation to any particular allegation to which a specific response has not been made.
2.Paragraph 1 is noted. I have had Accounts in the past with Ferratum UK Ltd.
3.Paragraph 2 is denied I am unaware of any legal assignment or Notice of Assignment allegedly served.
4.It is therefore denied with regards to the Defendant owing any monies to the Claimant,
the Claimant has failed to provide any evidence of assignment/balance/breach requested by CPR 31. 14,
Therefore the Claimant is put to strict proof to:
(a) show how the Defendant has entered into an agreement with the Claimant; and
(b) show how the Defendant has reached the amount claimed for; and
(c) show how the Claimant has the legal right, either under statute or equity to issue a claim;
5.As per Civil Procedure Rule 16.5(4), it is expected that the Claimant prove the allegation that the money is owed.
6.On the alternative, if the Claimant is an assignee of a debt, it is denied that the Claimant has the right to lay a claim
due to contraventions of Section 136 of the Law of Property Act and Section 82A of the consumer credit Act 1974.
7.By reasons of the facts and matters set out above, it is denied that the Claimant is entitled to the relief claimed or any relief.
Is this ok?, I only have a few days left to enter defence.
Don't touch them owe me £500 since January 2019 make excuse after excuse. Seem they always have software problems sending money out. Keep saying they will call back or email nothing been chasing it now for 6 mths the phone staff always have the same banter we will chase it up and get back to you then nothing!