I would be more comprehensive, something like this:
Regards the application, you probably won't file one because it would cost you £275 to do, but it's worth threatening them with it. Much cheaper to just defend and let them discontinue or lose at the hearing.
Dear Sirs
I have written to you on a number of occasions and you have yet to demonstrate that your client even have the legal right to bring a claim against me, let alone that I owe the alleged debt.
As you well know, to prove in court a debt is owed it is not sufficient to state that I ought to have received the terms of an agreement at some point in the past and it isn't sufficient to direct me to another organisation to obtain a copy of the notice that gives legal right to your client to bring a claim.
It is your client who must evidence each of these.
Therefore, for the avoidance of doubt, my position is that I do not owe this alleged debt and I will not be paying you or your client as such.
If it is the case your client wishes to test this matter in the County Court then I invite you to commence proceedings and I will file an application to strike it out on the basis that your client cannot prove they have a legal right to bring one, plus seek the costs of that application from your client.
Until such time as you or your client can evidence the terms of the alleged agreement, evidence Notice of Assignment from BT or commence proceedings, I will not engage in any further communications with you or them.
And should you or they continue to contact me by any method for any reason other than to evidence those items or commence proceedings, I will consider my position regards commencing proceedings without further notice against them pursuant to the Protection from Harassment Act 1997.
Your sincerely
I have written to you on a number of occasions and you have yet to demonstrate that your client even have the legal right to bring a claim against me, let alone that I owe the alleged debt.
As you well know, to prove in court a debt is owed it is not sufficient to state that I ought to have received the terms of an agreement at some point in the past and it isn't sufficient to direct me to another organisation to obtain a copy of the notice that gives legal right to your client to bring a claim.
It is your client who must evidence each of these.
Therefore, for the avoidance of doubt, my position is that I do not owe this alleged debt and I will not be paying you or your client as such.
If it is the case your client wishes to test this matter in the County Court then I invite you to commence proceedings and I will file an application to strike it out on the basis that your client cannot prove they have a legal right to bring one, plus seek the costs of that application from your client.
Until such time as you or your client can evidence the terms of the alleged agreement, evidence Notice of Assignment from BT or commence proceedings, I will not engage in any further communications with you or them.
And should you or they continue to contact me by any method for any reason other than to evidence those items or commence proceedings, I will consider my position regards commencing proceedings without further notice against them pursuant to the Protection from Harassment Act 1997.
Your sincerely
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