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money demands from someone who didnt preform the work, consumer rights

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Please could you post the entire claim form – in a good quality scanned condition – single file multipage PDF.

Please could you present them to us in the way that you would like someone else to present them to you.

Also, on 8 September you talked about receiving threats and I suggested that you email them to me but you haven't done.

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Sent the emails 


that is the claim form - how it came ,


the only way to make it neater is type it out myself -

it’s all jumbled like a rant with no dates ( just wrote 2021 everywhere ) 


Claim doesn’t actually state under what legal right he makes the claim - damages / breach of contract - 


just rants he’s not been paid ,

stating all this work and hours he did not do 


it’s all faulty ,

still broken and other electricians - tried in vain to connect it up and get it to work 


hence why we tried going through retailer for repair/


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Yes but we would like it properly scanned please in a single file with the entire document right from the beginning and not simply the extracts that you have published in two separate files.


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so here it is in one folder- the claim form attached 


want to do defence and counter claim today, to get off my desk

counter claim will be 


£2265 paid over for materials- system, not fit for purpose doesnt work and parts broken- still lays inoperable at front of house

200 circuit board - replacement bought to try and make system work as gate motors said it was broken what we had 

£90 sensors found broken so bought new ones to install

£600 consequential losses - other companies electricians bill to install gatesand electrics over 5 days- to no avail as parts wouldnt work

£130 gate posts damaged by claimant as he places a bracket in wrong location to gates against installation instruction-had to be moved, leaving damage

£? old stone wall damaged by bracket again in wrong place by claimant , against instructions and confirmed by specialists in email recently


rejected parts under consumer law - he cant return due to threats of damage and violence, so not in a position to repair or replace

what brackets/things he did attach to wall was without reasonable care and skill causing damage

beach of contract, he said im not coming back -get someone else (he has put this on his claim form!!!)

to note we also have an email saying have those few hours for free im not coming back to.




so what does he think his legal claim is?


i need

1) to write defence with correct legal jargon , but his particulars do not say under what legislation or right he claims

2) write counter claim with correct legal jargon



randle court claim.pdf

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Thank you.

Firstly, you don't need to start worrying about the fact that he hasn't mentioned a particular statute law legislation. It's quite sufficient that he is referred to an agreement and given a broad idea as to what the agreement is about and that he hasn't been paid.

The first thing you should do is you should file an acknowledgement with an intention to defend. That will extend the time for filing a defence from 14 days to 28 days.

Do that straightaway and confirm that it's been done.

Secondly, I suggest that you extract the text from his claim and put it into a two column Microsoft Word document. Put his text in the left-hand column and try to divide it into its paragraphs – point by point.

Each point or paragraph should occupy one row in the left-hand column. Opposite each row and effectively addressing each point made, please put in your own comments.
When that's done post it here

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no accurate or detailed timeline


link to invoice doesnt work, but anyways he didnt complete 90% of work he did six hours before walking off saying gets someone else, confirmed by himself i claim.


his statement

1) quoted work, customer agreed and paid deposit, came across some problems with unusual gate opening size and customer didnt want underground motors, we searched and searched and kept customer informed, we kept to our agreed price, although  many more hours spent on this job

got guy from checkatrade had to pay £100 just for a site visit and to obtain quote (texts retained)- first red flag, never had to pay for someone to win a job before. we chased for quote 9 april 2021 £came to £3165, £2165 materails plus £1000 labour (texts retained ), it came through , we said too high and didnt agree (texts retained), all motor stuff types etc irrelevant and discussed before getting this quote on 9th April 2021, no hours spent on quote and cost us £100!!!

we didnt pay a deposit he made us pay £2265 for quote materials, even against terms on his 'later provided' invoice ( large jobs require deposit of £1000)


2)works started and started well, 2 full days with two men, chased drive out and layed all cables, attached arms and motors in place, rain fell heavily on third day, so had to postpone

have text on day he was supposed to start wednesday 28april 2021, saying its raining ill try tomorrow afternoon, he turned up on his own for two hours that thurs afternoon and titvated, nothing really done at all.

Came back next morning friday 30/04/2021 with his brother, at 10am late, left at 1.30pm as 'it was friday he said' 

in that time two brackets on wall and three cables in floor laid loose , in channel, no wiring, no connections, no installation nothing.

chased him on monday 3/05/2021, where are you- 'oh i have parts missing, ill try and get back when they turn up. no show or parts for a couple of weeks.


3)moved jobs about causing a headache to get job done ASAP

so? you started and walked off giving misinformation and lies, never came back


4)client demanded vat reciepts from my suppliers so he can claim back , i said its in my name and business so not possible, now im being accused of hiding stuff eg cost etc, either way he excepted my quote, so really not sure why this was an issue, as he had every chance to seek other quotes, he knew every part i used as i kept him informed as he was constantly asking

we have text message dated 5/04/2021 before quote and any visits, we would require reciepts for vat as he was to charge us cost plus £1000 labour- he was well aware it was a requirement, he was hiding what was paid, gate motors confirmed he charged us way more and paid a much lesser amount on his credit card

seek other quotes after we paid him £100 for quote? he wouldnt provide those pre agreed in writing reciepts


5)due to the above we fell out , i was also having personal issues and i said find someone else 

yes have text 'have those few hours for free and find someone else, im never coming back 


6)soon after 1-2 days i asked for a reasonable part payment for works carried out, he said i havent fulfilled my contract, so i agreed to come back and he accepted, but as my date given was a few weeks away, he refused and said they dont feel confident in having me back, yet no other reason, no issues brought up along the way, and no real reason apart from they wanted to try and get done quicker or have current works done free, as he said he was going to do it himslef before i contracted him , so i suspect as i had done most of it dean could finish the easy bit and avid paying me, also not replying if not paid before going to court i will add £25 a week non payment plus full amount

text evidence 11 may (not 1-2 days after) asking for 80%, said no - nothings done , you walked out

he said fine ill come back with a deliberatly long date attached, sent text saying no good -large gate many Kgs heavy propped up by your dead tarmac bag, dangerous to us and public-put this in writing, he said ok , ill do it earlier he didnt even turn up on earlier alotted day he suggested said dont trust him to turn up now at all, hes had his chances, everything is dangerous

then have those few hours for free text from him , because i wont give you reciepts or ever come back to people who dont trust me 


found another installer, they were visiting to quote 17th may 2021 , they came and found parts missing and broken, we rang him stupidly to find out where missing parts were, we had paid lots of money in advance for ? torrent of abuse 

on phone leading to email abuse and crime reference from police- emailed to admin of this site over 18-19th may 2021


although new guys spent 5 days (meant to be three for £400) costing us £600, gates still wont work, we  had to buy new motors, circuit boards, sensors, trying to claim of retailer as well under third party rights.


so no working gates still and parts faulty, not fit for purpose, suitable all money taken by this trader in advance who has the nerve to try and claim off us









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No I would hold off if I were you.

I think you are going at it too quickly. You should start off sending the acknowledgement and then we will work things out afterwards.

Apart from anything else, in your defence you are not identifying the important points in the claim and merely addressing those. You are launching into narrative which is not relevant and makes it more difficult for anybody including the court – and including me to understand.

You are attempting to adopt some kind of professional style but I'm sorry to say that it comes over as strutting and unnecessary. You are litigant in person and you have a certain licence and you should try to profit from that by keeping things simple.

Are you a limited liability company?

Why have you redacted the name of the person who is suing you? Are you trying to protect them? 

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Not trying to protect anyone -

thats my problem with forms ,

I say too much , and need to condense down ,

which is where I need the help - to make it simpler - bullet point answers , but it’s hard to respond to his points which aren’t clear either-



I would like to send defence and

counter claim now rather than hold off , as I am determined now to get all our money back , so want to get the counter claim started ASAP

if possible and get the ball rolling 


This was a personal Installation at

home address -

not through any company , just as a consumer 



Edited by MOSS 41
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I don't think that rushing anything off will particularly accelerate any process.
It would certainly have been easier if you had presented your commentary in the tabulated form that I asked.

I'm afraid that we do everything here for free and there are many people to help and we try to do what we can when we can.

You should certainly send the acknowledgement straightaway but I think that your defence and counterclaim can be much better than they are.

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If you are intending to counter claim then your defence and counter claim or Part 20 claim should be in a certain format and one page....not separate. I agree with BF just acknowledge service for now get the full 33 days to consider and prepare.



We could do with some help from you.



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If you want advice on your Topic please PM me a link to your thread

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Also, I asked you if you are suing as a company – but you haven't answered. I also asked you about the threats and if you would send them to me in confidence by email – and you didn't deal with that either.

It really would help if you would respond to these questions even if to say that you prefer not to say

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Sorry but we haven't received anything. Would you mind trying again – to our admin email address.

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It will be helpful if you would answered very simply the following points in his claim:

  1. he quoted for certain work
  2. you agreed to the work
  3. you paid a deposit
  4. he discovered that the required gate was unusual
  5. you didn't want underground motors
  6. he searched for an alternative solution and capture inform
  7. he kept to the agreed price
  8. he worked for two full days and with two men
  9. he chased the drive out
  10. he laid all cables
  11. he attached Arnesen motors in place
  12. obliged to postpone because of rain
  13. you asked for VAT receipts
  14. he said that he had bought the material in his own business name
  15. you have now suggested that he is trying to avoid certain costs or taxes
  16. he says that you knew every part that he was using
  17. he says that he kept you informed because you are constantly asking questions
  18. he says he was having personal issues and so he told you to find someone else
  19. after that he asked for reasonable part payment for work carried out
  20. you told him that he hadn't fulfilled the contract
  21. he agreed to come back and you accepted
  22. his date for returning to the work was not acceptable to you
  23. you said that you are going to do the work yourself
  24. you are capable of finishing what was yet to do

please could you do this in the tabulated form I've already suggested and which you decline to do so far.
Please can you answer each point shortly without a load of narrative


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I'm sorry but if you won't present it in a tabular form as I've asked, then I'll close the thread.
We try to give you the best help you can it seems to me at the moment a lot of effort is being spent simply getting you to address questions or to present documents clearly or to cooperate with us in understanding your case clearly and arranging your defence and counterclaim in the most effective way.

If you were paying £300 an hour for this advice I expect that you would comply PDQ.

I understand that you are probably busy – but maybe should understand that we are as well. We have our work commitments, and family commitments in addition to being constantly on-call giving free help to people on this forum.

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I've received the email thank you

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I'm not asking you to mind read – but I am asking you to go back to the post which I made about nine hours ago which is probably post number 32 where I asked you to present information in a tabular form and even described how to do it.

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I've looked through the email threats that you sent me. Although they are unpleasant, I think that they amount merely to insults and an aggressive posture and I'm afraid I don't think that anybody would consider that it was worth acting on in the way of threats.

I suppose it shows a certain attitude but I don't think it does anything more than that.

I hope you are going to produce the tabulated commentary that I asked and then we can go forward and draft a defence and also discuss your counterclaim

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