Hunts motors Bedford - Faulty Car cambelt failed - i won by default/sent HCEO's - they paid in full - now set aside as court errored - new Hearing

[Doingmybest]

Email from Hunt's motors:

Yes we both parties need to submit our defence by 29th August and than hearing is taking place in October 2023.

It has costed me with bailiffs and court fees £4162 if you willing to pay half we can close this matter outside the court.

Financially, we are not out of pocket. This will happen if we pay the fees for a new trial we will be.

We have not refunded anything.

Regarding the court error, i was not aware that he was not getting his post so could not include it in the statement.

Okay, so I need to do a new statement.
 

[Doingmybest]

Should I just read to the witness statement that I did?

 

[dx100uk]

you stick to your org POC and your WS yes.

dont let them intimidate you. if they try and have a little chat before you walk in..walk away.

BUT i also think you need to bring up that this situation would not have existed had the court not errored.

[Dizzydizzy123]

Surely any business would have put a mail forwarding system on with Royal Mail? 

[Doingmybest]

Thanks dx. 
do I submit them as one document or as separate documents?

[dx100uk]

so didnt read the events to date properly, you've yet to send your statement ..good. 

 

 

[Doingmybest]

Just received the defendants statement,

tried to post it up as a pdf but it says that the file is too large.

 

 

Edited August 16, 2023 by Doingmybest

[FTMDave]

Use  https://www.ilovepdf.com/compress_pdf

 

[Doingmybest]

Here is the defendant statement. 

Hunts motors statement _compressed.pdf

[dx100uk]

what about the exhibits?

pop up those we have not already seen please.

their English is terrible! and not sure about this 30 days moneyback thing...totally irrelevant and does not negate, override nor remove your rights under consumer law. and i dont think you've ever said the belt had snapped/broken but had issues? loose tensioners faulty...etc etc

[Doingmybest]

On 18/05/2022 at 12:21, Doingmybest said:

 

AA called out to car on 07.04.2022 and informed us that the timing belt has gone and possibly caused damage to engine.

These a list of their exhibits.

I'll need to do my statement and post it up.

Hunts motors defence exhibits.pdf

[Doingmybest]

hi,

Just realised that this has to be in on Friday. Just been really busy and overwhelmed with everything. Can someone please take a look and tell me what I need to correct?

WITNESS STATEMENT OF CLAIMANT

 

………………………………………………………………………………………………………………………………

 

I, xxxxxx of xxxxxx, have been given the authority to act on behalf of my son xxxxxx who is the Claimant in this claim. The facts in this statement come from my personal knowledge of dealing with the defendant and court case.

 

 

1.         This witness statement is made by the claimant in response to the defendant's Statement to the court.

 

2.         The defendant states that because the claimant reported the fault after 30 days of purchase that they had no further responsibility to the claimant:

 

a.     The claimant requested a repair or full refund of the purchase price of £2900 on the grounds that the goods were not of satisfactory quality under the Consumer Rights Act 2015.

 

b.     The defendant refused to repair and/or refund the cost stating that they only offer a 3-month warranty and were not going to address the issues.

 

c.      The defendant totally disregarded the Consumer Rights Act 2015.

 

3.         The defendant accuses the claimant of lying about the broken cambelt. The car broke down away from the claimant’s home and the RAC were called. The RAC mechanic informed the claimant that the cambelt had failed and catastrophic damage could be caused to the engine if further attempts to try and start the car were made. An independent mechanic was called to assess the car and they confirmed the fault after examination.

 

4.         The defendant maintains that they were “totally unaware of judgement as they did not receive notification about the hearing.”  The defendant maintains that they received no communication from the court after May 2022 and had also changed their address. The claimant finds this hard to believe as any business would put in place a mail forwarding system.

 

5.         If what the defendant is saying about not receiving correspondence is to be believed, this situation would not have existed if the court had not made an error in recording the defendants address.

 

The Court Claim

 

 4.     The Claimant issued a claim against the defendant on the 11.05.2022:

 

a.     The claimant requested a repair or full refund of the purchase price of £2900 on the grounds that the goods were not of satisfactory quality under the Consumer Rights Act 2015.

 

b.     The defendant refused to repair and/or refund the cost stating that they only offer a 3-month warranty and were not going to address the issues.

 

c.      The defendant totally disregarded the Consumer Rights Act 2015.

5.     Mediation between the parties was scheduled for the 8th of June 2022. I refer to the [email correspondence dated 20th May 2022 timed at 11:08] which is now shown marked B.

 

 6.     The defendant states that they moved premises so did not receive any correspondence from the court.

 

 7.     The defendant’s new address is in the same town at around 12 miles from their previous one.

 

 8.     The claimant does not believe that a business would move premises without arranging to have mail forwarding in place.

 

 9.     Despite the move, the defendant participated in mediation on the 8th June 2022 and as no resolution was reached, they were fully aware that the case was moving to a hearing.

 

10.     On the 26.07.2022, the court ordered that the claimant ‘re-serve’ an updated form N225 to the defendant. This was posted by Royal Mail special delivery on 2nd September 2022 and signed for by ‘ALI’ who the claimant believes to be an operative of the defendant’s business - Hunts Motors LTD on 5th September 2022 at 10:54am. I refer to the [Royal Mail proof of delivery certificate dated 5 September timed at 10:54] which is marked C.

 

11.     On the 1st December 2022 The claimant received email confirmation from the court that Judgment had been entered and the order was posted and received by both parties. I refer to the [email dated 1st December 20:22 timed at 07:29] which is now shown marked D.

 

12.  The claimant received the notification of the judgement in January 2023 and instructed the HCEO. I refer to the [judgement dated 10th November 2022] which is now shown marked E.

 

13.  The claimant does not believe that the defendant received no notifications from the court either by post or by email; even if this was the case, the defendant had been corresponding with the court regarding their defence and during the mediation process.

 

14.  It was the defendant’s responsibility to check with the court that the case had been dismissed or was still ongoing, and to inform the court of any change of address.

 

The Defendant's Defence

 

15.  The defendant has requested a new hearing to set aside judgment and “defend themselves” the claimant does not believe that another hearing is required.

16.  Even if the court were to accept that the defendant really had not received court orders, the fact is that the defendant would have no chance of successfully defending the claim.

 

17.  The defendant did not adhere to the law as stated clearly in the Consumer Rights Act 2015 and refused to repair or offer a full refund of the purchase price on the grounds that the goods were not of satisfactory quality and not fit for purpose.

 

18.  As a consumer, the claimant was entitled to a repair or to return the car for a full refund under the Act which was refused by the defendant.

 

19.  The defendant simply has no defence in law.

 

Statement Of Truth:

 

I believe that the facts stated in this witness statement are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.

[FTMDave]

That's not bad at all.  There's a bit of repetition and a few bits that aren't relevant, but these can be seen to.

But an immediate question.  Why are you complicating things with "I , xxxxxx of xxxxxx, have been given the authority to act on behalf of my son xxxxxx who is the Claimant in this claim"?  Why doesn't your son simply put his name on the WS and sign it?

[Doingmybest]

Thank you. I think because I’ve been doing it all for him. 
Do you think it should just have his name on it and then ask the judge’s permission to act for him on the day?

 

4 hours ago, FTMDave said:

That's not bad at all.  There's a bit of repetition and a few bits that aren't relevant, but these can be seen to.

But an immediate question.  Why are you complicating things with "I , xxxxxx of xxxxxx, have been given the authority to act on behalf of my son xxxxxx who is the Claimant in this claim"?  Why doesn't your son simply put his name on the WS and sign it?

I'll take another look through and tidy it up.

I need to send it off tomorrow.

[FTMDave]

I haven't got the detailed legal knowledge of Bankfodder or Andyorch, so I'm not sure exactly how "bad" it would be, but immediately a red flag shot up.  A claimant going into court with a Witness Statement not actually written by the claimant is a gift to the other side.  They're bound to cast doubt on its accuracy, saying a person not involved in the dispute has written the thing.  It's better and easier not to give them this gift.

Plus, you know he has to be in court, right?  There are ways of accompanying someone to court, but he has to be there and to be prepared to answer questions from the judge and from Hunt's.

11 minutes ago, Doingmybest said:

I'll take another look through and tidy it up.

I need to send it off tomorrow.

I'll help this evening if the others don't pop in.

[Doingmybest]

Many thanks.

Totally makes sense.

[Doingmybest]

Is this any better?

1.    This witness statement is made by the claimant in response to the defendant's Statement to the court. 

2.    The defendant states that because the claimant reported the fault after 30 days of purchase that they had no further responsibility to the claimant:

a.     The claimant requested a repair or full refund of the purchase price of £2900 on the grounds that the goods were not of satisfactory quality under the Consumer Rights Act 2015.

b.     The defendant refused to repair and/or refund the cost stating that they only offer a 3-month warranty and were not going to address the issues.

c.      The defendant totally disregarded the Consumer Rights Act 2015.

3.    The defendant accuses the claimant of lying about the broken cambelt. The car broke down away from the claimant’s home and the RAC were called. The RAC mechanic informed the claimant that the cambelt had failed and catastrophic damage could be caused to the engine if further attempts to try and start the car were made. An independent mechanic was called to assess the car and they confirmed the fault after examination.

4.    The claimant put trust in the defendant who is the ‘motor trader’ who advised at the point of sale that the car had been through a full service and within that would’ve serviced the car in accordance with manufacturer’s instructions: to include the relevant and necessary replacement of parts at certain intervals. The Cambelt is not something that can be easily checked by the consumer or purchaser of the car. Any reasonable person purchasing a car from a motor trader would expect and trust that the motor trader would be aware of the manufacturers service intervals and the components that require changing and when they should be changed. It cannot be the responsibility of the purchaser.

5.    Once the defendant retrieved the vehicle from the claimant, they readvertised it and sold it for £3290.00. The advertisement stated, “Service History, Cambelt and water pump just been replaced @100k”. This indicates that the defendant is fully aware of service intervals and the manufacturers recommendations. 

6.    The defendant maintains that they were “totally unaware of judgement as they did not receive notification about the hearing.”  The defendant maintains that they received no communication from the court after May 2022 and had also changed their address. The claimant finds this hard to believe as any business would put in place a mail forwarding system.

7.    If what the defendant is saying about not receiving correspondence is to be believed, this situation would not have existed if the court had not made an error in recording the defendant’s address. 

8.    The defendant contacted the claimant saying: “It has costed me with bailiffs and court fees £4162 if you willing to pay half we can close this matter outside the court”. The claimant believes that this signifies the defendant only wants to profit from this case instead of doing what it lawful: the defendant had already advertised and successfully sold the car for £3290.

The Court Claim

 4.     The Claimant issued a claim against the defendant on the 11.05.2022:

a.     The claimant requested a repair or full refund of the purchase price of £2900 on the grounds that the goods were not of satisfactory quality under the Consumer Rights Act 2015.

b.     The defendant refused to repair and/or refund the cost stating that they only offer a 3-month warranty and were not going to address the issues.

c.      The defendant totally disregarded the Consumer Rights Act 2015.

5.     Mediation between the parties was scheduled for the 8th of June 2022. I refer to the [email correspondence dated 20th May 2022 timed at 11:08] which is now shown marked B.

 6.     The defendant states that they moved premises so did not receive any correspondence from the court.

 7.     The defendant’s new address is in the same town at around 12 miles from their previous one.

 8.     The claimant does not believe that a business would move premises without arranging to have mail forwarding in place.

 9.     Despite the move, the defendant participated in mediation on the 8th June 2022 and as no resolution was reached, they were fully aware that the case was moving to a hearing.

10.     On the 26.07.2022, the court ordered that the claimant ‘re-serve’ an updated form N225 to the defendant. This was posted by Royal Mail special delivery on 2nd September 2022 and signed for by ‘ALI’ who the claimant believes to be an operative of the defendant’s business - Hunts Motors LTD on 5th September 2022 at 10:54am. I refer to the [Royal Mail proof of delivery certificate dated 5 September timed at 10:54] which is marked C. 

11.     On the 1st December 2022 The claimant received email confirmation from the court that Judgment had been entered and the order was posted and received by both parties. I refer to the [email dated 1st December 20:22 timed at 07:29] which is now shown marked D. 

12.  The claimant received the notification of the judgement in January 2023 and instructed the HCEO. I refer to the [judgement dated 10th November 2022] which is now shown marked E.

13.  The claimant does not believe that the defendant received no notifications from the court either by post or by email; even if this was the case, the defendant had been corresponding with the court regarding their defence and during the mediation process. 

14.  It was the defendant’s responsibility to check with the court that the case had been dismissed or was still ongoing, and to inform the court of any change of address.

The Defendant's Defence

15.  The defendant requested a new hearing to set aside judgment and “defend themselves”.

16.  Even if the court were to accept that the defendant really had not received court orders, the fact is that the defendant would have no chance of successfully defending the claim.

17.  The defendant did not adhere to the law as stated clearly in the Consumer Rights Act 2015 and refused to a repair or offer a full refund of the purchase price on the grounds that the goods were not of satisfactory quality and not fit for purpose as is their duty according to the consumer rights act 2015.

18.  As a consumer, the claimant was entitled to a repair or to return the car for a full refund under the Act which was refused by the defendant.

19.  The defendant simply has no defence in law.

Statement Of Truth:

I believe that the facts stated in this witness statement are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.
 

[FTMDave]

OK, let's look at the latest version.

I haven't followed this thread as closely as some of the other regulars, so check any ideas for accuracy.  IIRC you won by default but then Hunt's managed to get judgement set aside.

If you possibly can, wait until Bankfodder or Andyorch have had the chance to look in before sending it off.

A lot of it is repetition or irrelevant.  A new judge won't give a toss as to why the default judgment was set aside.  The judge will only be interested if your case is better than Hunt's.

The first part from 1 to 8.

In (2 c) I would quote the part of the Act you are relying upon.

In (3), if you have any written evidence from the RAC or the independent mechanic, it needs to be included as an exhibit.  The exhibits have to be given numbers and referred to in your WS, e.g. " An independent mechanic was called to assess the car and they confirmed the fault after examination (Exhibit 2)". 

In (5) again attach an exhibit.  Make the point that if there really was no problem with the cambelt, then why change it?

(6) & (7) are completely irrelevant to this new hearing.

The second part from 4 to 14.

This whole lot is either repetition (4) or completely irrelevant to the new hearing (5-14).  The matter of the set aside has already been adjudicated upon.  A new judge won't give a monkey's.

The third part from 15 to 19.

(15) & (16) again irrelevant.  The rest superb.

[Doingmybest]

Wow it seems like it's been really if not brutally trimmed down. Is this better:

WITNESS STATEMENT OF CLAIMANT

………………………………………………………………………………………………………………………………

1.    This witness statement is made by the claimant in response to the defendant's Statement to the court. 

2.    The defendant states that because the claimant reported the fault after 30 days of purchase that they had no further responsibility to the claimant:

a.     The claimant requested a repair or full refund of the purchase price of £2900 on the grounds that the goods were not of satisfactory quality under the Consumer Rights Act 2015.

b.     The defendant refused to repair and/or refund the cost stating that they only offer a 3-month warranty and were not going to address the issues.

c.      The defendant totally disregarded the Consumer Rights Act 2015: The Consumer Rights Act stipulates that dealers will only get one chance to repair or replace the product, so dealers can’t make multiple attempts to fix a problem unless otherwise agreed. The claimant reasonably gave the defendant the opportunity to remedy the fault but they refused to do so saying that their contract out weighs the consumer rights act.  

3.    The defendant accuses the claimant of lying about the broken cambelt. The car broke down away from the claimant’s home and the RAC were called. The RAC mechanic informed the claimant that the cambelt had failed and catastrophic damage could be caused to the engine if further attempts to try and start the car were made. An independent mechanic was called to assess the car and they confirmed the fault after examination.

4.    The claimant put trust in the defendant who is the ‘motor trader’ who advised at the point of sale that the car had been through a full service and within that would’ve serviced the car in accordance with manufacturer’s instructions: to include the relevant and necessary replacement of parts at certain intervals. The Cambelt is not something that can be easily checked by the consumer or purchaser of the car. Any reasonable person purchasing a car from a motor trader would expect and trust that the motor trader would be aware of the manufacturers service intervals and the components that require changing and when they should be changed. It cannot be the responsibility of the purchaser.

5.    Once the defendant retrieved the vehicle from the claimant, they readvertised it and sold it for £3290.00. The advertisement stated, “Service History, Cambelt and water pump just been replaced @100k”. This indicates that the defendant is fully aware of service intervals and the manufacturers recommendations. which is now shown marked X.

6.    The defendant contacted the claimant saying: “It has costed me with bailiffs and court fees £4162 if you willing to pay half we can close this matter outside the court”. The claimant believes that this signifies the defendant only wants to profit from this case instead of doing what it lawful: the defendant had already advertised and successfully sold the car for £3290.

The Defendant's Defence

7.  The defendant did not adhere to the law as stated clearly in the Consumer Rights Act 2015 and refused to a repair or offer a full refund of the purchase price on the grounds that the goods were not of satisfactory quality and not fit for purpose as is their duty according to the consumer rights act 2015.

8.  As a consumer, the claimant was entitled to a repair or to return the car for a full refund under the Act which was refused by the defendant.

9.  The defendant simply has no defence in law.

Statement Of Truth:

I believe that the facts stated in this witness statement are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.
 

 

just to add, I don't have any reports from the mechanic or the rac. I can prove that we called out the RAC but that's about it. 

[FTMDave]

There is no reason for the WS to be massively long.  The case is clear cut.

They say you are lying about the cambelt (an appalling choice of words which will seriously unimpress the judge).

You have evidence that the cambelt was knackered.  That's what you need to emphasise.

Beef up the bits you can -

3 hours ago, FTMDave said:

In (5) again attach an exhibit.  Make the point that if there really was no problem with the cambelt, then why change it?

Change " The Defendant's Defence" title to "Conclusion".

Surely you have receipts at least for the RAC and the independent mechanic?

 

I've found these excellent points from the first page of your thread -

Proof of full service history not provided as indicated in the advert and promised by the dealer.

He did not receive evidence of full service history.

He has a partial history with last stamp being 2014.

Also the dealer again informed us that the car had a full service at time of sale.

AA called out to car on 07.04.2022 and informed us that the timing belt has gone and possibly caused damage to engine.

I wrote to the dealer twice with no response until I sent letter before action:

they refused to do anything

said that there was only a 3 month warranty.

My son did around 2000 miles.

Apart from the dealer saying that they had serviced the car there is no evidence that the car has had a service since 2014 or cambelt change.

Ford have informed me that the belt should be changed every 8 years or 100,000 miles -which ever comes sooner.

as this failed within 6mts of ownership and was sold very close to the cambelt change date and they claimed it had a full service history, under cra 2015 you have a very good chance. the 2k miles and 5mts ownership is in your favour too.

[Doingmybest]

wow thank you.

 

 

 

[dx100uk]

stuff in red is all good so is your current version of a statement.... mix it all in but keep it succinct and brief to each the point.

forget the set aside its done and dusted it was granted.

 

 

[Doingmybest]

Thanks for the help last night.

I've made changes and merges. There are repetitions but not sure if it harms things.

 

 

WITNESS STATEMENT OF CLAIMANT

 

………………………………………………………………………………………………………………………………

 

 

1.       This witness statement is made by the claimant in response to the defendant's Statement to the court. 

 

2.       The history of the claimant’s claim is as follows:

 

                                               i.     Proof of full-service history not provided as indicated in the advert and promised by the dealer. [original Autotrader advert] which is now shown marked A.

 

                                             ii.     The claimant did not receive evidence of full-service history, instead there was a partial history with last stamp being 2014.

 

                                            iii.     The defendant continuously maintained that the car had a full service at time of sale.

 

                                            iv.     The vehicle broke down and the Claimant called out the AA on the 07.04.2022 who informed the claimant that the timing belt had gone and possibly caused damage to engine.

 

                                             v.     The Claimant wrote to the dealer twice with no response [initial emails] which is now shown marked B

 

                                            vi.     Letter before action sent. [letter before action] which is now shown marked C

 

                                          vii.     The defendant refused to do anything and repeated that they offered a 3 month warranty. [Defendant final response] which is now shown marked D.

 

                                         viii.     The claimant completed around 2000 miles before the car failed.

 

                                            ix.     Despite the defendant maintaining that they had serviced the car there is no evidence that the car has had a service since 2014 or cambelt change.

 

                                              x.     The manufactory informed the claimant that the cam belt Ford have informed me that the belt should be changed every 8 years or 100,000 miles -which ever comes sooner. The defendant claimed that the car had received a full service prior to sale and the assumption that they as the motor trader are professionals, a reasonable person would believe that they would’ve changed the cam belt in accordance to the manufacturer’s instructions.

 

3.       The defendant states that because the claimant reported the fault after 30 days of purchase that they had no further responsibility to the claimant:

 

a.     The claimant requested a repair or full refund of the purchase price of £2900 on the grounds that the goods were not of satisfactory quality under the Consumer Rights Act 2015.

 

b.     The defendant refused to repair and/or refund the cost stating that they only offer a 3-month warranty and were not going to address the issues.

 

c.      The defendant totally disregarded the Consumer Rights Act 2015: The Consumer Rights Act stipulates that dealers will only get one chance to repair or replace the product, so dealers can’t make multiple attempts to fix a problem unless otherwise agreed. The claimant reasonably gave the defendant the opportunity to remedy the fault, but they refused to do so saying that their contract outweighs the consumer rights act.  

 

4.       The defendant accuses the claimant of lying about the broken cambelt. The car broke down away from the claimant’s home and the AA were called. The AA mechanic informed the claimant that the cambelt had failed and catastrophic damage could be caused to the engine if further attempts to try and start the car were made. An independent mechanic was called to assess the car and they confirmed the fault after examination.

 

5.       The claimant put trust in the defendant, the ‘motor trader’ who advised at the point of sale that the car had been through a full service and within that would’ve serviced the car in accordance with manufacturer’s instructions: to include the relevant and necessary replacement of parts at certain intervals. The Cambelt is not something that can be easily checked by the consumer or purchaser of the car. Any reasonable person purchasing a car from a motor trader would expect and trust that the motor trader would be aware of the manufacturers service intervals and the components that require changing and when they should be changed. It cannot be the responsibility of the purchaser.

 

6.       Once the defendant retrieved the vehicle from the claimant, they readvertised it and sold it for £3290.00. The advertisement stated, “Service History, Cambelt and water pump just been replaced @100k”. This indicates that the defendant is fully aware of service intervals and the manufacturers recommendations. which is now shown marked X.

 

 

7.       The defendant contacted the claimant saying: “It has costed me with bailiffs and court fees £4162 if you willing to pay half, we can close this matter outside the court”. The claimant believes that this signifies the defendant only wants to profit from this case instead of doing what it lawful. [email dated August 2^nd] Now shown marked E

 

8.       The defendant had already advertised and successfully sold the car for £3290. [Advert for resale of car] Now shown marked F

 

9.       DVLA website shows that the car has been taxed and MOT. [DVLA] Now shown marked G

 

 

Conclusion

 

7.  The defendant did not adhere to the law as stated clearly in the Consumer Rights Act 2015 and refused to a repair or offer a full refund of the purchase price on the grounds that the goods were not of satisfactory quality and not fit for purpose as is their duty according to the consumer rights act 2015.

 

8.  As a consumer, the claimant was entitled to a repair or to return the car for a full refund under the Act which was refused by the defendant.

 

9.  The defendant simply has no defence in law.

 

Statement Of Truth:

 

I believe that the facts stated in this witness statement are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.

Exhibits for Case.docx

[FTMDave]

Pernickety, but instead of A, B, C, etc, it should be Exhibit A, Exhibit B, Exhibit C, etc.

In (2 x) there are some words to cut out.

You need to tweak the numbering in "Conclusion".

Are "timing belt" and "cambelt" the same thing?  Forgive me, I'm the world's worst for being ignorant about what goes on under a car bonnet.  If so, change "timing belt" in (2 iv) to be consistent.

Apart from these tiny things, it looks fine to me - well done.

It's quite a simple case for a judge.  Was the cambelt knackered or not?  If so, were your CRA rights respected or not?  Anything you emphasise on these points is important.  And you have done so repeatedly.

In (6) add - "Clearly there was a serious problem with the cambelt as I have maintained all along, otherwise the defendant would not have replaced it".  Your exhibit here needs to be numbered and added to the list.

Any proof you have of the AA and the independent mechanic need to be included.  I know you have no report.  But anything to back up your story would be good.  Receipts?  Phone records?  Name of independent mechanic?

[Doingmybest]

Many thanks and much appreciated.

I will of course update once there is any news.