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ConcernedExpat09

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Yes thats why I stated in my last post " edit to suit....post it back here for opinions."

 

Don't go secret squirrel like the others...you saw how their claims ended up.


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6months ago that was 

 

 

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Not going secret squirrel! I will get sorted and post over weekend or by Monday. I need to submit by Friday 

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quick notes on the fly:

even though you don't mean the CCA [consumer credit act]

I would not use that in 3 but say agreement...just to remove any confusion.

 

 

 


..

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12 minutes ago, dx100uk said:

quick notes on the fly:

even though you don't mean the CCA [consumer credit act]

I would not use that in 3 but say agreement...just to remove any confusion.

 

 

 

Good spot my bad. 

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Question: 

 

ive checked paperwork 

it’s states a skeleton argument should be returned no later than 3 days prior to the date of hearing.

 

is this the same as the witness statement? 
 

or do they both need to be submitted?

 

if so do Witness Statements have to be submitted 7 days prior? 

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An Application/hearing of this kind does not normally require a skeleton argument...yes its 7 days pre hearing your statement must be filed and served.


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Ah ok 

 

thanks Andy.

The letter re: the hearing stated that they could put one across and then if I want to respond I can do as long as 24 hours before the hearing 

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A Skeleton is only of use in particular complicated trial hearings...its basically a synopsis of your defence and witness statement and the bullet points you will rely on.....hearings for Summary Judgment/Strike out mainly relies on the statement you submit and evidence relied upon and the hearings are normally a lot shorter than normal trial hearings.

 

See if they serve one on you...then you can decide if you wish to respond.


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Hi all

 

Been served a skeleton along with the pack again for the CMCC hearing.

they want the strike out regardless 

 

is it worth me sending back a skeleton argument and stating again that I offered to pay? 
 

They are purely after their fees now. 
Will also contact Emirates Directly explaining this. 

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1 hour ago, ConcernedExpat09 said:

Hi all

 

Been served a skeleton along with the pack again for the CMCC hearing. What pack ?

they want the strike out regardless Regardless of what..what has changed ?

 

is it worth me sending back a skeleton argument and stating again that I offered to pay? Again ? have you stated that in your witness statement ?
 

They are purely after their fees now. Of course they are..they were on the other 2 claims...thats why they do Summary Judgment rather than trial
Will also contact Emirates Directly explaining this. Explaining what ? You deal with the Solicitors not the claimant 

 

 

Andy


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15 minutes ago, dx100uk said:

can we see it please..pdf

 

The issue I have is I can’t redact it all as there are around 100 of pages of statements etc

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Witness statement should be 2 pages tops and and any exhibits 3/4......copy of the N244 would also be useful...we dont need statements.


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The pack is for the Cost Managment hearing which they want to run if the summary judgment isn’t given.

 

when I said regardless they aren’t interested in settling even though it would be in their interest. 
 

Yes in Witness Statement I posted here I explained I have tried to settle.

 

I don’t believe they are contacting Emirates with any proposals or settlements as they are only after their £32k in fees.

 

With the CCJ being granted it will be. A lose lose situation for all. 

 

I’m away this evening I will do tomorrow morning when back and post asap 

 

Thanks again 

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There is no cost management hearing...this is a a hearing for Summary Judgment....we deal with this type of application daily.


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Copy of their Skeleton would also be interesting to see.


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Thanks thats great...yes the was an adjourned Costs Hearing and they will do them together now....apologies I had forgotten about it.


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Let me read through the statement properly tomorrow and then check yours again and I will post any  recommended amendments 

 

If you could upload their Skeleton and any exhibits referred to in their statement .


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So it is....reads like a further witness statement.......I cant find any exhibits in your previous uploads or above.....in particular the actual credit agreement they refer to in their WS.

 

Andy


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