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By BMX bandit · Posted
OK Folks, I'm back from holiday and have prepared the CPR31 letter per the template and will be sending it today So I have 2 weeks to file the defence, Is this fairly straightforward to complete and are the words below still considered the latest and most effective version of response, Thinking in particular of any case law since 2012 that could further support it and someone mentioned earlier that loading is not parking - is that worthy of a mention at this stage or do I keep the powder dry? "The Defendant contends that the particulars of claim are vague and generic in nature which fails to comply with CPR 16.4. The Defendant accordingly sets out its case below and relies on CPR r 16.5 (3) in relation to any particular allegation to which a specific response has not been made. 1. The Defendant is the recorded keeper of [motor vehicle]. 2. It is denied that the Defendant entered into a contract with the Claimant. 3. As held by the Upper Tax Tribunal in Vehicle Control Services Limited v HMRC [2012] UKUT 129 (TCC), any contract requires offer and acceptance. The Claimant was simply contracted by the landowner to provide car-park management services and is not capable of entering into a contract with the Defendant on its own account, as the car park is owned by and the terms of entry set by the landowner. Accordingly, it is denied that the Claimant has authority to bring this claim. 4. In any case it is denied that the Defendant broke the terms of a contract with the Claimant. 5. The Claimant is attempting double recovery by adding an additional sum not included in the original offer. 6. The Particulars of Claim is denied in its entirety. It is denied that the Claimant is entitled to the relief claimed or any relief at all." -
You'd think it would be more efficient to routs excess water from local rivers into local aquifers which are apparently under major strain but I haven't investigated that at all - but we'd just be filling them up with poo encrusted water from the water (protect our dividends) debt mountain companies wouldn't we - - - mind you isnt that a bonus for farming use? then again, if fracking gets gets the go ahead theres no point as they will be poisoned ... ah but fracking wont be allowed around Tunbridge Wells will it .. so ... Lots of angles to thing about.
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Did they comply with your cca request? Did anyone?
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By Strawberry_candy33 · Posted
Cabot are threatening me with a CCJ Apparently my details were selected by their lawyers. Is it another threatogram? Since Cabot own the debt and not the original creditor, can they still apply for one ? -
no and i wont be recommending what toilet paper to use nor how too either. enough nurse maiding already. cag is predominantly self help. dx
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