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    • name of claimant is not overdales - a solicitor representing a client cannot be the claimant.   pop up on the MCOL website detailed on the claimform. [if mcol is not working return after the w/end or the next day if week time] .  register as an individual on the Gov't Gateway Site Go to HMRC's login page. Click the GREEN sign in button. Click “Create sign in details” Enter your email address where asked. You will now be emailed a confirmation code. ... You will now be issued with a User ID for your government gateway account.  note down your details inc the long gateway number given, you might need it later.  then log in to the MCOL Website .  select respond to a claim and select the start AOS box. .  then using the details required from the claimform .  defend all  leave jurisdiction unticked  you DO NOT file a defence at this time [BUT you MUST file a defence regardless by day 33 ] click thru to the end confirm and exit MCOL. .. get a CCA Request running to the claimant https://www.consumeractiongroup.co.uk/topic/332502-cca-request-consumer-credit-act-1974-updated-january-2015/ .. Leave the £1 PO unsigned and uncrossed . get a CPR  31:14  request running to the solicitors [if one is not listed send to the claimant] ... .[use our other CPR letter if the claim is for an OD or Telecom Debt] . https://www.consumeractiongroup.co.uk/topic/332546-legal-cpr-3114-request-request-for-information-when-a-claim-has-been-issued/ . on BOTH type your name ONLY Do Not sign anything . you DO NOT await the return of ANY paperwork  you MUST file a defence regardless by day 33 from the date on the claimform [1 in the count] ..............      
    • Which Court have you received the claim from Northampton N1   Name of the Claimant ? Overdales   Date of issue –  31/12/2021   Date to submit defence  - 2nd February    Particulars of Claim   1. claim comprises of the following agreements the defendant entered into: a) shop direct financial services current balance £937 B) shop direct financial services current balance £3742   2. The agreements were terminated as payments were not maintained and subsequently assigned to the claimant A) total sums = £4679 B) interest pursuant of s69 £374 c) costs   What is the total value of the claim? £4680 = with court costs and interest = £5609   Have you received prior notice of a claim being issued pursuant to paragraph 3 of the PAPDC (Pre Action Protocol) ? YES   Have you changed your address since the time at which the debt referred to in the claim was allegedly incurred? NO   Did you inform the claimant of your change of address? N/A Is the claim for - a Bank Account (Overdraft) or credit card or loan or catalogue or mobile phone account? CATALOGUE   When did you enter into the original agreement before or after April 2007 ? AFTER 2007   Do you recall how you entered into the agreement...On line /In branch/By post ? ONLINE   Is the debt showing on your credit reference files (Experian/Equifax /Etc...) ? YES   Has the claim been issued by the original creditor or was the account assigned and it is the Debt purchaser who has issued the claim. DEBT PURCHASER (LOWELLS HAVE THE DEBT AND OVERDALES ARE ACTING ON THEIR BEHALF)   Were you aware the account had been assigned – did you receive a Notice of Assignment? NOT SURE IT'S BEEN A WHILE 3 YEARS IN DEBT AT LEAST   Did you receive a Default Notice from the original creditor? NOT SURE IT'S BEEN A WHILE 3 YEARS IN DEBT AT LEAST   Have you been receiving statutory notices headed “Notice of Sums in Arrears”  or " Notice of Arrears "– at least once a year ? NO   Why did you cease payments? WAS WITH A DEBT CHARITY (STEPCHANGE) MAKING PAYMENTS TO A NUMBER OF DEBTERS WIFE LOST 2ND JOB AND COULD NO LONGER AFFORD PAYMENTS (STEP CHANGE SUGGESTED I GO BANKRUPT I DIDN'T WANT TO DO THAT) CAME TO CAG FOR ADVICE IT WAS SUGGESTED I DROPPED THE CHARITY AND WENT ON MY OWN. FOUND IT EASIER SOME DEBTS ARE BEING PAID SOME CAN'T GET CCA INFO SO NOT HEARD FROM THEM FOR AGES OVERDALES HAVE BEEN THE ONLY PERSISTANT ONES FOR THIS DEBT.   What was the date of your last payment? CAN'T REALLY REMEMBER BUT PERHAPS 2017 OFF THE TOP OF ME HEAD   Was there a dispute with the original creditor that remains unresolved? AT THE TIME WHEN WIFE LOST HER JOB THEY WOULDN'T REDUCE PAYMENTS INSTEAD PILED ON INTEREST AND FINES. ENDED UP NOT RESPONDING TO THEM ANYMORE AND BEEN IN DEBT SINCE TO DCA'S   Did you communicate any financial problems to the original creditor and make any attempt to enter into a debt management plan? YES I DID AND THEY WEREN'T INTERESTED
    • So many memories of listening to his tracks when I was younger, also making me feel rather old as well
    • whoever said send an sar to the fleecers or their dogs, waste of time, thats what CCA/CPR does.   you should NEVER EVER be sending ANY covering letter to anyone that tips them off how you might later defend a claim you've been here far to long to now be making such schoolboy mistakes ALWAYS check with us before you do anything!.   can you get that link done please?   WHEN you have done that we will advise your next steps.   your defence will be our generic one slightly adapted which is in just about every 'CAT claimform' thread here.   use our enhanced google search box.   you dont file anything with a defence disclosure come at the witness statement stage IF IF IF it ever gets that far.   i strongly suggest you go read a few 10's of cat claimform threads here so you know what is to come, how to react, and the various stages of the court claim. please other than filing out our link, dont ever do anything more without checking here FIRST but DO NOT ever miss your defence filing date which we dont even know yet!!          
    • @dx100uk   I have filled everything  I can online against the claim apart from my defence yet. I still have a few weeks for this. I am defending the whole claim.   I filled out another CCA form and a CPR 31.14 to Overdales and sent this recorded last week with a covering letter. I also did a SAR to Lowells which haven't even signed for the letter looking at the RM tracker.   Overdales wrote to me today sending me copies of the same S78 as shown in #6 post above. (if you wouldn't mind taking another look and seeing if they have sent enough or is something missing?)   In the covering letter I told them that the only information they have supplied is copies of a digitally signed agreement with Very and a copy of the T&C relating to that. I am missing things like notice of assignment, default notice and any copies of statements relating to the account. I also mentioned that they claim over £3000 on a littlewoods account and haven't supplied any information relating to this account at all.   So they ignored all that and just sent me the same files as last time and have told me they won't discuss the account anymore only to arrange payment or take it to court.   So it looks like the court route.   I can defend the claim online upto 1000 words can you submit documentation to the court as evidence e.g attachments or would this be done in person on the day or write to them with the documentation?
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Cabot court claim - 2003 Lloyds Loan


sxam
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Hi all,

 

I have been silently following this forum for sometime as I was in lot of debt in and around 2003 and I was with Euro Debt paying token payments

 

. With lot of information from this site, I started sending CCA request to my creditors in September 2017. I was in debt management plant until then. I stopped all token payment from September 2017, since all of them failed to comply with my request.

 

 I have been getting letters and threat-o-gram from different DCA, that didn't bother me much.

 

Now I received claim form for one of my debt.

I do not acknowledge this debt which is in the region of £8700

 

. I did receive PAP from their solicitor on 16th December but the amount on the PAP was for £3200.

 

I failed to reply to the PAP (apologies for my ignorance) as I didn't think it was necessary as they never sent me the agreement. I simply wrote a letter to them saying account is in dispute for failing to supply agreement.

 

My answers for the questions below.

Please suggest how I should take this forward.

Appreciate your help.

Thank you.

 

Name of the Claimant ? Cabot

 

Date of issue –  29 January 2021

  

Particulars of Claim

 

What is the claim for – the reason they have issued the claim? 

1.By an agreement between Lloyds Banking Group & the Defendant on or around 13/05/2003 (‘the Agreement’) Lloyds Banking Group agreed to loan the Defendant monies.

 

2.The Defendant did not  pay the instalments as they fell due. 

 

3.The Agreement was terminated following the service of a default notice.

 

4.The Agreement was assigned to the Claimant. The Claimant therefore claims £8704.42 and costs.

  

What is the total value of the claim? £9214.42
 

Have you received prior notice of a claim being issued pursuant to paragraph 3 of the PAPDC (Pre Action Protocol) ? Yes however I failed to send the PAP back. I only sent a letter saying the account is in dispute for failing to fulfil CCA request. PAP they send was for £3200, however their claim is almost three times that.
 

Have you changed your address since the time at which the debt referred to in the claim was allegedly incurred? Yes
 

Did you inform the claimant of your change of address? yes

Is the claim for - a Bank Account (Overdraft) or credit card or loan or catalogue or mobile phone account? Loan, however I cannot find the amount on any of the communication.
 

When did you enter into the original agreement before or after April 2007 ? Yes
 

Do you recall how you entered into the agreement...On line /In branch/By post ? In Branch
 

Is the debt showing on your credit reference files (Experian/Equifax /Etc...) ? No
 

Has the claim been issued by the original creditor or was the account assigned and it is the Debt purchaser who has issued the claim. Debt Purchaser (Cabot, through Mortimer Clarke)
 

Were you aware the account had been assigned – did you receive a Notice of Assignment? Yes 

Did you receive a Default Notice from the original creditor? Unsure
 

Have you been receiving statutory notices headed “Notice of Sums in Arrears”  or " Notice of Arrears "– at least once a year ? No
 

Why did you cease payments? They failed to supply CCA 

 

What was the date of your last payment? August 2017
 

Was there a dispute with the original creditor that remains unresolved? Give answer here
 

Did you communicate any financial problems to the original creditor and make any attempt to enter into a debt management plan? Yes, I was on debt management plan until September 2017. I stopped all payment from the time they failed to comply with my CCA request.

 

 

 

 

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pop up on the MCOL website detailed on the claimform.
[if mcol is not working return after the w/end or the next day if week time]
.
 register as an individual on the Gov't Gateway Site
 note down your details inc the long gateway number given, you might need it later.
 then log in to the MCOL Website
.
 select respond to a claim and select the start AOS box.
.
 then using the details required from the claimform
.
 defend all
 leave jurisdiction unticked
 you DO NOT file a defence at this time
[BUT you MUST file a defence regardless by day 33 ]
click thru to the end
confirm and exit MCOL.
..
get a CCA Request running to the claimant

https://www.consumeractiongroup.co.uk/topic/332502-cca-request-consumer-credit-act-1974-updated-january-2015/

..

Leave the £1 PO unsigned and uncrossed

.

get a CPR  31:14  request running to the solicitors [if one is not listed send to the claimant]
...
.[use our other CPR letter if the claim is for an OD or Telecom Debt]
.

https://www.consumeractiongroup.co.uk/topic/332546-legal-cpr-3114-request-request-for-information-when-a-claim-has-been-issued/

.

on BOTH type your name ONLY
Do Not sign anything
.
you DO NOT await the return of ANY paperwork 
you MUST file a defence regardless by day 33 from the date on the claimform [1 in the count]

..............


 

please don't hit Quote...just type we know what we said earlier..

DCA's view debtors as suckers, marks and mugs

NO DCA has ANY legal powers whatsoever on ANY debt no matter what it's Type

and they

are NOT and can NEVER  be BAILIFFS. even if a debt has been to court..

If everyone stopped blindly paying DCA's Tomorrow, their industry would collapse overnight... 

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Thank you dx,

Do I again send CCA request even though I sent it back in September 2017? Cabot replied saying they don't have it and they need to request it from Lloyds, but I have never heard back since then. 

 

Problem I have is, I only had one loan with Lloyds and Apex is dealing with this debt.

Cabot took over Lloyds credit card debt in the region of £2900.

They sent PAP for £3200 but now claim is for £8700.

The sums do not add up.

 

I will acknowledge the claim and send them CPR letter.

 

Once again, appreciate your help. Thank you.

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and a CCA.

 

apex are a powerless dca why are you blindly paying them anything!!

a dca is not a bailiff!!

 

start a new topic on it .

 

please don't hit Quote...just type we know what we said earlier..

DCA's view debtors as suckers, marks and mugs

NO DCA has ANY legal powers whatsoever on ANY debt no matter what it's Type

and they

are NOT and can NEVER  be BAILIFFS. even if a debt has been to court..

If everyone stopped blindly paying DCA's Tomorrow, their industry would collapse overnight... 

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Hi Dx,

 

I haven't paid any penny to any DCA since 2017. Apex gone quiet since they could not produce an agreement. Reason I mentioned Apex on this thread is because they are the only DCA dealing with Lloyds Loan. So this claim from Cabot does not make any sense, the amount is wrong, debt type is wrong etc

 

I will pop in CCA along with CPR. I have already done the AOS.

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well the debt might have been sold since then

Apex dont buy debts

they only operate from their stated client as ambulance chasers.

 

have you moved in recent times and not informed people?

 

please don't hit Quote...just type we know what we said earlier..

DCA's view debtors as suckers, marks and mugs

NO DCA has ANY legal powers whatsoever on ANY debt no matter what it's Type

and they

are NOT and can NEVER  be BAILIFFS. even if a debt has been to court..

If everyone stopped blindly paying DCA's Tomorrow, their industry would collapse overnight... 

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I haven't moved for sometime now and they always wrote me on the current address. Probably Apex sold it to Cabot. Probably CPR reply might shed some light.

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apex don't buy debt

they only chase for their stated clients...said that in above post

 

so who was their client?

probably not still the original creditor as it was from 2003 and i bet sold by lloyds around the time of the default in ??

 

please don't hit Quote...just type we know what we said earlier..

DCA's view debtors as suckers, marks and mugs

NO DCA has ANY legal powers whatsoever on ANY debt no matter what it's Type

and they

are NOT and can NEVER  be BAILIFFS. even if a debt has been to court..

If everyone stopped blindly paying DCA's Tomorrow, their industry would collapse overnight... 

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It looks like Apex gave the account back to Lloyds after my CCA request. Lloyds then passed it on to Cabot but I never received a letter of assignment nor have I received PAP for this amount.

 

Now my question is, I did AOS yesterday, does 14 days starts from tomorrow to file the defence or I still get 33 days from the date on the claim form?

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as in post 2......

 

pop up on the MCOL website detailed on the claimform.
[if mcol is not working return after the w/end or the next day if week time]
.
 register as an individual on the Gov't Gateway Site
 note down your details inc the long gateway number given, you might need it later.
 then log in to the MCOL Website
.
 select respond to a claim and select the start AOS box.
.
 then using the details required from the claimform
.
 defend all
 leave jurisdiction unticked
 you DO NOT file a defence at this time
[BUT you MUST file a defence regardless by day 33 ]
click thru to the end
confirm and exit MCOL.
..
get a CCA Request running to the claimant

https://www.consumeractiongroup.co.uk/topic/332502-cca-request-consumer-credit-act-1974-updated-january-2015/

..

Leave the £1 PO unsigned and uncrossed

.

get a CPR  31:14  request running to the solicitors [if one is not listed send to the claimant]
...
.[use our other CPR letter if the claim is for an OD or Telecom Debt]
.

https://www.consumeractiongroup.co.uk/topic/332546-legal-cpr-3114-request-request-for-information-when-a-claim-has-been-issued/

.

on BOTH type your name ONLY
Do Not sign anything
.
you DO NOT await the return of ANY paperwork 
you MUST file a defence regardless by day 33 from the date on the claimform [1 in the count]

..............

^^

please don't hit Quote...just type we know what we said earlier..

DCA's view debtors as suckers, marks and mugs

NO DCA has ANY legal powers whatsoever on ANY debt no matter what it's Type

and they

are NOT and can NEVER  be BAILIFFS. even if a debt has been to court..

If everyone stopped blindly paying DCA's Tomorrow, their industry would collapse overnight... 

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  • 3 weeks later...

Thank you DX, not far away from filing the defence. This is what I have prepared for now. Can you please caste your eye over to see if this is all good to file?

Cheers.

 

 

Particular Of claim

 

1. By an agreement between Lloyds Banking Group & the defendant on or around 13/05/2003 (“the agreement”) Lloyds Banking Group agreed to loan the defendant monies.

 

2. The defendant did not pay the instalments as they fell due. The agreement was terminated following service of a default notice.

 

3. The agreement was assigned to the claimant.

 

4. THE CLAIMANT THEREFORE CLAIMS:

1) £8704.42

2) COSTS

 

Defence

 

The Defendant contends that the particulars of claims 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 allegation to which a specific response has not been made.

 

The Claimant has not complied with paragraph 3 of the PAPDC (Pre Action Protocol) - Failed to serve a letter of claim pre claim pursuant to PAPDC changes of the 1st October 2017. It is respectfully requested that the court take this into consideration pursuant to 7.1 PAPDC.

 

1.I have in the past had financial dealings with Lloyds Banking Group. I do not recall the precise details of the agreement and have sought clarity from the claimant.

 

2.However, I do not recall ever receiving a Default Notice pursuant to sec 87(1) CCA1974.

 

3. However I do not recall ever receiving this notice pursuant to sec136 of the Law of Property Act 1925.

 

4. However, I do not recall ever receiving letter of assignment from the Lloyds Banking group advising the debt was assigned to the claimant.

 

5. On receipt of this claim I sent CPR 31.14 and section 78 request. The claimant failed to provide a valid copy of the agreement and therefore remains in default of said request.

 

6. It is therefore not accepted with regards to the Defendant owing any monies to the Claimant and the Claimant is put to strict proof to:-

 

a) show how the Defendant has entered into an agreement ; and

b) show how the Defendant has reached the amount claimed for; and

c) Show or evidence service of a Default Notice/Notice of Sums in Arrears,

d) show how the Claimant has the legal right, either under statute or equity to issue a claim;

 

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.

 

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On 06/02/2021 at 14:33, sxam said:

I did receive PAP from their solicitor on 16th December but the amount on the PAP was for £3200.

 

I failed to reply to the PAP (apologies for my ignorance) as I didn't think it was necessary as they never sent me the agreement. I simply wrote a letter to

 

You also need to remove the repeated use of however.

 

Ive added para no's to their poc above too to make it easier

Dx

please don't hit Quote...just type we know what we said earlier..

DCA's view debtors as suckers, marks and mugs

NO DCA has ANY legal powers whatsoever on ANY debt no matter what it's Type

and they

are NOT and can NEVER  be BAILIFFS. even if a debt has been to court..

If everyone stopped blindly paying DCA's Tomorrow, their industry would collapse overnight... 

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13 minutes ago, dx100uk said:

 

You also need to remove the repeated use of however.

 

Ive added para no's to their poc above too to make it easier

Dx

Thank you DX,

 

PAP received was was for completely different amount with different reference, should I say i received PAP or can i decline receiving it? There was nothing to suggest the PAP was for this debt.

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really... so no link with any same ref number nor creditor etc etc.

do you still have it?
 

please don't hit Quote...just type we know what we said earlier..

DCA's view debtors as suckers, marks and mugs

NO DCA has ANY legal powers whatsoever on ANY debt no matter what it's Type

and they

are NOT and can NEVER  be BAILIFFS. even if a debt has been to court..

If everyone stopped blindly paying DCA's Tomorrow, their industry would collapse overnight... 

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:rockon:

please don't hit Quote...just type we know what we said earlier..

DCA's view debtors as suckers, marks and mugs

NO DCA has ANY legal powers whatsoever on ANY debt no matter what it's Type

and they

are NOT and can NEVER  be BAILIFFS. even if a debt has been to court..

If everyone stopped blindly paying DCA's Tomorrow, their industry would collapse overnight... 

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Good to go DX? Shall I mention current account PAP or file the defence as above saying no PAP received. 

 

Last day of defence is 3rd of March, Should I leave it till the end and file it or do it now? 

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CCA request for loans are section 77 not section 78.....and you will have to mention that they served an invalid PAP with no connection to the their court claim.

 

Andy

We could do with some help from you.

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take your time sxam, not due till 4pm the 2nd.

better to get it nice and tight and correct 

please don't hit Quote...just type we know what we said earlier..

DCA's view debtors as suckers, marks and mugs

NO DCA has ANY legal powers whatsoever on ANY debt no matter what it's Type

and they

are NOT and can NEVER  be BAILIFFS. even if a debt has been to court..

If everyone stopped blindly paying DCA's Tomorrow, their industry would collapse overnight... 

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Thank you Andy/Dx

 

UPDATED Defence, 3 days remaining.

 

Not sure where to mention invalid PAP. I put it under number 5. Please check if this is good to go.

 

Defence
 
The Defendant contends that the particulars of claims 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 allegation to which a specific response has not been made.
 
The Claimant has not complied with paragraph 3 of the PAPDC (Pre Action Protocol) – failed to serve a letter of claim pre-claim pursuant to PAPDC changes of the 1st October 2017. It is respectfully requested that the court take this into consideration pursuant to 7.1 PAPDC.
 
1. I have in the past had financial dealings with Lloyds Banking Group. I do not recall the precise details of the agreement and have sought clarity from the claimant.
 
2. However, I do not recall ever receiving a Default Notice pursuant to sec 87(1) CCA1974.
 
3. I do not recall ever receiving this notice pursuant to sec136 of the Law of Property Act 1925.
 
4. I do not recall ever receiving a letter of assignment from the Lloyds Banking group advising the debt was assigned to the claimant.
 
5. Claimant served the invalid PAP with no connection to their court claim,
 
6. On receipt of this claim I sent CPR 31.14 and section 77 request. The claimant failed to provide a valid copy of the agreement and therefore remains in default of said request.
 
7. It is therefore not accepted with regards to the Defendant owing any monies to the Claimant and the Claimant is put to strict proof to:-
 
a) show how the Defendant has entered into an agreement; and
b) show how the Defendant has reached the amount claimed for; and
c) Show or evidence service of a Default Notice/Notice of Sums in Arrears,
d) show how the Claimant has the legal right, either under statute or equity to issue a claim;
 
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.
 
 

 

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I was going through the defence briefly and saw option for counterclaim. Do I counterclaim? What do i need to pay attention to while filing a defence?

 

Thank you.

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not due till tuesday by 4pm.

await its checking 1st please as i see thats not 100% right 

 

but not you do not counterclaim.

simply copy and past the text from here into the box after hitting enter defence.

 

slowdown... no rush

 

 

please don't hit Quote...just type we know what we said earlier..

DCA's view debtors as suckers, marks and mugs

NO DCA has ANY legal powers whatsoever on ANY debt no matter what it's Type

and they

are NOT and can NEVER  be BAILIFFS. even if a debt has been to court..

If everyone stopped blindly paying DCA's Tomorrow, their industry would collapse overnight... 

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Share on other sites

Particular Of claim

 

1. By an agreement between Lloyds Banking Group & the defendant on or around 13/05/2003 (“the agreement”) Lloyds Banking Group agreed to loan the defendant monies.

 

2. The defendant did not pay the instalments as they fell due. The agreement was terminated following service of a default notice.

 

3. The agreement was assigned to the claimant.

 

4. THE CLAIMANT THEREFORE CLAIMS:

1) £8704.42

2) COSTS

 

 

Defence

 

The Defendant contends that the particulars of claims 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 allegation to which a specific response has not been made.
 
1.The Claimant has not complied with paragraph 3 of the PAPDC (Pre Action Protocol) – failed to serve a letter of claim pre-claim pursuant to PAPDC changes of the 1st October 2017.It is admitted that the claimant has sent details of a current account with an unknown account number but has no connection to this this claim or alleged debt. It is respectfully requested that the court take this into consideration pursuant to 7.1 PAPDC.
 
2. Paragraph 1 is noted. I have in the past had financial dealings with Lloyds Banking Group. I do not recall the details of alleged debt the claimant refers to nor have they referred to any account number within its particulars. I have therefore sought clarity from the claimant and requested further in formation which at this time they failed to comply to my request.
 
3. Paragraph 2 is noted. However, as above the alleged debt is still unknown and further I do not recall ever receiving a Default Notice pursuant to sec 87(1) CCA1974.
 
4.Paragraph 3 is noted. As above as the debt is unknown its immaterial and I do not recall ever receiving this notice pursuant to sec136 of the Law of Property Act 1925.
 
5. On receipt of this claim I sent CPR 31.14 and section 77 request. The claimant has failed to comply with either requests and in particular my section 77 request and provide a valid copy of the agreement and therefore remains in default of my request and is prevented from enforcing the agreement they wish to rely on.
 
7. It is therefore not accepted with regards to the Defendant owing any monies to the Claimant and the Claimant is put to strict proof to:-
 
a) show how the Defendant has entered into an agreement; and
b) show how the Defendant has reached the amount claimed for; and
c) Show or evidence service of a Default Notice/Notice of Sums in Arrears,
d) show how the Claimant has the legal right, either under statute or equity to issue a claim;
 
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.
 
 
 
.
 
 
 
 
 
 
 
 

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