Claim Form Lowell for Paypal Europe & Capital One Europe

[echat11]

Im sorry were completely lost with all this as we have never got this far before

Prepare a Witness Statement with evidence sorry and You can object to the lifting of the stay in your Witness Statement with other points.do u have any links to a template etc because as ive said we dont know what were doing

Thanks

Have a read of the following thread, that is what you need to prepare - https://legalbeagles.info/forums/for...ps-help-please

Update the thread when you've had a read and made notes.

[junkmanukuk]

Hi

Thanks for the reply

This is going to take some time to get my head around and sink in

How long would u say i have to compose a witness statement and get it sent to them even though i dont know the outcome of the initial court case

Also what does lifting of the stay mean in relation to my case?

Why are they providing a Claimants supplementary witness statement after the court date and i dont think we have ever actually ever received a witness statement from them before the hearing date

[echat11]

Hi

Thanks for the reply

This is going to take some time to get my head around and sink in

How long would u say i have to compose a witness statement and get it sent to them even though i dont know the outcome of the initial court case

Also what does lifting of the stay mean in relation to my case?

Why are they providing a Claimants supplementary witness statement after the court date and i dont think we have ever actually ever received a witness statement from them before the hearing date

a) How long would u say i have to compose a witness statement and get it sent to them even though i dont know the outcome of the initial court case

Exactly right, there are 'unknowns', we don't know the outcome of the Hearing, but it's good to have a Witness Statement with the facts that you have and amend it when you receiver any material information from them. A couple of weeks.

b) Also what does lifting of the stay mean in relation to my case?

My error, the link was posted so you could see the structure of the Witness Statement.

c) Why are they providing a Claimants supplementary witness statement after the court date and i dont think we have ever actually ever received a witness statement from them before the hearing date

It may have something to do with the last Hearing on the 8th July, they are probably addressing matters they haven't covered previously.
Email the creditors solicitor, ask them for copy of the previous Witness Statement.

[junkmanukuk]

Many Thanks

It may have something to do with the last Hearing on the 8th July, they are probably addressing matters they haven't covered previously.
Email the creditors solicitor, ask them for copy of the previous Witness Statement.

Will do shall i also mention that they still havent provided a copy of the Default Notice per my CPR 31.14 request of shall i not mention it?

Thanks

[echat11]

Many Thanks

It may have something to do with the last Hearing on the 8th July, they are probably addressing matters they haven't covered previously.
Email the creditors solicitor, ask them for copy of the previous Witness Statement.

Will do shall i also mention that they still havent provided a copy of the Default Notice per my CPR 31.14 request of shall i not mention it?

Thanks

Yes, post it on the thread without personal details.

[junkmanukuk]

Does this sound ok

Please can you send me a copy of your previous Witness Statement as i haven't received one as yet only the one dated 15th July 2025

Also you still haven't provided me with a copy of the Default Notice per my CPR 31.14 request that was sent to you on 09/07/2024

Many Thanks


I just want to make sure im doing it right from now on

Thanks

[echat11]

Does this sound ok

Please can you send me a copy of your previous Witness Statement as i haven't received one as yet only the one dated 15th July 2025

Also you still haven't provided me with a copy of the Default Notice per my CPR 31.14 request that was sent to you on 09/07/2024

Many Thanks


I just want to make sure im doing it right from now on

Thanks

Please can you send me a copy of your previous Witness Statement as I never received it. The only one I received is dated 15th July 2025.

I wouldn't add the following, as that needs to go in your Witness Statement. You requested it, they didn't send it, if they had it.

Also you still haven't provided me with a copy of the Default Notice per my CPR 31.14 request that was sent to you on 09/07/2024

[junkmanukuk]

Thanks

Have a nice weekend

Many Thanks

[junkmanukuk]

Hi

Just recieved a email with there original witness statement

They say

8. The Claimant believes the Defendant would have been given the opportunity to bring Account 1 up to date by paying the overdue amount. The Claimant requested the Default Notice, and the Notice of Sums in Arrears from PayPal, however, the documents were not available.


9. The Claimant’s information states Agreement 1 defaulted on or around 12 June 2023. A copy of the Default Notice has been requested from the PayPal, however, a copy was unavailable at this time.

How can i attach a pdf or send you a copy of it

Thanks

[echat11]

Hi

Just recieved a email with there original witness statement

They say

8. The Claimant believes the Defendant would have been given the opportunity to bring Account 1 up to date by paying the overdue amount. The Claimant requested the Default Notice, and the Notice of Sums in Arrears from PayPal, however, the documents were not available.


9. The Claimant’s information states Agreement 1 defaulted on or around 12 June 2023. A copy of the Default Notice has been requested from the PayPal, however, a copy was unavailable at this time.

How can i attach a pdf or send you a copy of it

Thanks

You don't need to, you've highlighted what they say. The important thing is to prepare a Witness Statement that covers the 3 accounts and the Hearing date so the Witness Statement is ready in good time.

[junkmanukuk]

OK

Thanks

[junkmanukuk]

Hi

Ive done a draft witness statement please can u have a look and advise

Thanks



IN THE MANCHESTER COUNTY COURT

Claim No




BETWEEN:

Claimant

Lowell Financial Limited




AND

Defendant






_________________________________




WITNESS STATEMENT OF

_________________________________










I , being the Defendant in this case will state as follows;




I make this Witness Statement in support of my defence in the claim.




1. On or around the 10 JUN 2024, I received a claims form from the Civil National Business Centre, Northampton, for the amount of £3561.93




2. The particulars of claim state that this claim is for “ Agreements the Defendant entered into

1. PayPal Europe Sarl & Cie SCA a Balance of £2742.74
2. Capital One a Balance of £280.02
3. Capital One a Balance of £254.17

3. There were no details about when the alleged default occurred or details as to how the sums claimed have accrued




4. The particulars of claim fail to state when the agreement was entered into.



5. On 2nd July 2024 I made a formal written request to the Claimant solicitors Overdales requesting that the Claimant provides copies of all documents mentioned in the statement of case under CPR 31.14



6. On 2nd July 2024 I made a formal written request to the Claimant for them to provide me with a copy of my 1. Agreement 2. Default Notices 3. Notice of Assignment under sections 77-79 of the Consumer Credit Act 1974 and also enclosed a payment of £3.00 which represents the fee payable under the Consumer Credit Act



7. On the 8th July 2024, I sent my response to the court, acknowledging the claim and informing them that I wished to dispute the claim in its entirety.




8. I am still to receive the Default Notice, and the Notice of Sums in Arrears for the PayPal account




9. On the 17th July 2025 I received the Claimants supplementary witness statement ( I am still waiting on there original witness statement)




10. On 18 July 2025 I emailed the Claimants solicitors and requested there original witness statement




11. The Claimant replied to my request on 21 July 2025 by email and provided me with there original Witness statement dated 11th June 2025




12. After reading the Claimants Original Statement it states that (The Claimant requested the Default Notice, and the Notice of Sums in Arrears from PayPal, however, the documents were not available) it also states that (The Claimant’s information states Agreement 1 defaulted on or around 12 June 2023. A copy of the Default Notice has been requested from the PayPal, however, a copy was unavailable at this time).







Statement of Truth




I the Defendant, believe the facts stated within this Witness Statement to be true.







Signed: ________________________________




Dated: ________________________________




************************************************** *******************************************

[echat11]

Will do.

[junkmanukuk]

Many Thanks

[junkmanukuk]

Hi

We have just received a letter from the court please see attached pic

Did u mange to look out our witness statement?

Thanks

PXL_20250728_154106508~2.jpg