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So you need to get this finalised and submitted by Friday 4.00pm......I would run with the following. Defence 1.The Defendant contends that the particulars of claim are vague and generic in nature. The claimant even fails to refer to an agreement number. Therefore 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 2 is noted. Whilst I have had dealings with Barclaycard given that claimant fails to refer to an account number I am unaware what agreement the claimant wishes to rely upon. 3.Paragraph 3 is noted although without knowledge of which account the claimant refers to I can neither admit or deny the receipt of a Default Notice pursuant to sec 87(1) CCA1974 being received 4. Paragraph 4 is noted but again as above I am not aware of what agreement the assignment refers to. 5. On receipt of this claim I requested information pertaining to this claim from PRA group (UK) Ltd by way of a CPR 31:14 request sent via 1st class recorded post on 27/06/2022 and further to the above I sent PRA group (UK) Ltd a section 78 request via 1st class recorded post on 27/06/2022. To date, PRA Group Ltd are yet to furnish me with the requested information and therefore prevented from enforcing the alleged agreement. 6.Therefore with the court’s permission the Claimant is put to strict proof to evidence and : a) show and disclose how the Defendant has entered into an agreement; b) show and disclose how the Claimant has reached the amount claimed for; c) show and evidence the nature of breach and service of a Default Notice pursuant to Sec 87 (1) CCA1974. d) show how the Claimant has the legal right, either under statute or equity to issue a claim; 8. As per Civil Procedure Rule 16.5 (4) it is expected that the Claimant prove the allegation that the money is owed. 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. Andy Question: Can we put anything about these debts being purchased for like 10% of their value (from what I've heard) Question 2: Can we put as defence that she does not have any income presently
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planning permission too. i bet the org granted was 3hrs, no-one can change that with council perm. dx
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Industrial action in Norway could suspend gas deliveries to a terminal on the East Yorkshire coast.View the full article
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By aliencontractor · Posted
Yep that is a mistake on our part unfortunately
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