Please read me, running out of time

[Baronstoneybroke]

OK> I have had a claim against Lloyds which was settled with all the usual b****cks of privacy etc.

However, as the claim was being discussed for settlement at the usual last minute as is Lloyds custom they proposed to pay it into the account with a further £270 in charges that had acumulated and a further £30 being in the pipeline.

 

I told their solicitor to pay into another account to avoid further litigation. They would in fact have had to sue me for their charges.

 

However they would not budge on this point and their solicitor said to sort it out post-case.

 

On being approached I was met with a blank refusal. I sent them a letter again and received another refusal.

 

So I have started action for £300 on the grounds that Lloyds have not kept their word.

 

I have received this new approach from their solicitors (not those of the first case) as follows:-

 

Defence

1. The Defendant will object that the Particulars of Claim in this action disclose no reasonable cause of action against the Defendant and makes no allegation against the Defendant as to why the Defendant should be liable to the Claimant.

 

2. The Defendant are Bankers carrying on business at their Hereford branch and elsewhere and whose registered office is 25 Gresham Street, London, EC2V 7HN.

 

3. No admissions are made as to the Particulars of Claim.

 

5. As the Particulars of Claim generally, the losses are inadequately particularised. The Defendant is unable to admit or deny any losses allegedly suffered by the Claimant, but denies that such losses were caused by any actionable wrongdoing on the part of the Defendant. Further or alternatively, the losses claimed are too remote to be recoverable.

 

6. In the premises the Defendant denies that they are as alleged in the Particulars of Claim liable to the Claimant for the sums claimed.

 

7. The Defendant requires the Claimant to be put to strict proof of his claim.

 

8. Save as is herein expressly admitted or not admitted the Defendant denies each and every allegation in the Statement of Claim as if the same were set out herein and separately traversed.

 

(note that there is no para. 4)

 

I have read the thread re. 'the losses are inadequately particularised' but this is slightly different as I am complaining out of a previous case.

 

I have my letters to the Bank and their refusals. I have copies of my emails to Martineau Johnson but their replies were by phone. However you can see the general drift of the conversation by reading the stuff I have.

 

Basically, how should I play it? reply to the AQ as per the thread and point out that they refused twice to talk to me and should they decide to talk then I have copies of correspondence to hand.

 

that they are aware of the grounds of the claim as it refers to a claim that was in hand at the time this money was taken and if the Bank has failed to instruct the solicitors of this then that is their fault (and responsibility) and not mine.

 

That all solicitors and bankers should be drowned at birth ( sorry, I know I cannot add that but I had to get it off my chest)

 

And anything else you can think of.