Court Claim - AJJB Law

[jsstar]

Hi,

Have received a court claim as below and very grateful for any advice.

Received a claim? Yes/No: Yes

Issue Date: 1/07/25

Have you Acknowledged the Claim?: Yes

Total Amount Claimed : £500

Claimant’s Name: COEO Securitisation Limited As Assignee of ONMO Ltd

Solicitors Firm: AJJB Law

Original Creditor: ONMO

Original Debt: Credit Card

Particulars of Claim:


The Claimant is the assignee of Onmo Limited.

The Claimant's claim is as an assignee of monies due under a regulated finance agreement entered into between Onmo Limited and the Defendant. Full details of the monies due have been supplied to the Defendant. and the Claimant claims

1. xxxxxxx.

2. Statutory interest pursuant to Section 69 of the County Courts Act (1984) at a rate of 8.000% per annum from 27/06/25 to 30/06/25 0.00, and thereafter at a daily rate of 0.00 to date of judgment or sooner payment.

Invoice date 27/06/25

Ref. xxxxx

The claimant claims interest under section 69 of the County Courts Act 1984 at the rate of 8% a year from 26/06/2025 to 29/06/2025 on £xxxx and also interest at the same rate up to the date of judgment or earlier payment at a daily rate of £0.00.



Is the debt Statute Barred: No

List any letters you have sent (eg: CCA/ CPR ): CCA & CPR

Any Other Information or Background Details: Requested the CCA after Letter Before Claim but received nothing back.

Thank You!

[echat11]

a) First Acknowledge Service of the Claim, you can do this online via MCOL, this will give you 28 days (plus 5 days postal) in total to work on your defence - you've stated that you've done this.

https://legalbeagles.info/library/gu...ledge-a-claim/

b) Send a SAR request to ONMO, they have 30 days to provide all the data they hold on the account. Make sure you get Proof of Postage.

https://legalbeagles.info/library/gu...ccess-request/

c) Send a CCA request to COEO Securitisation Limited they have 12 days to provide a copy of the agreement. Make sure you get Proof of Postage.

https://legalbeagles.info/library/gu...etter-example/

d) Send a CPR 31.14 request to AJJB Law, they have 7 days to provide all the documents they are relying on to make the claim against you, again get Proof of Postage.

https://legalbeagles.info/library/gu...-of-documents/

e) This is an example Defence, start looking at it, don't fill or file it with the Court or their solicitors yet.

https://legalbeagles.info/library/gu...-court-claims/

Don't speak to creditors, solicitors etc over the phone, everything in writing. Keep on top of this, especially dates for filing defence etc. Workout when your Defence is due, 28 days from the date on the claim form. If you can post on the thread 5 days before it's due we can help with your Defence.

[jsstar]

Thanks echat11 ,

All of the above was done on 5th July - I have yet to hear back from ONMO or COEO or AJJB . My defence is due on 29th July.

Shall I draft up now or wait a few more days for a response?

Thank You

[echat11]

Thanks echat11 ,

All of the above was done on 5th July - I have yet to hear back from ONMO or COEO or AJJB . My defence is due on 29th July.

Shall I draft up now or wait a few more days for a response?

Thank You

Wait a few more days, but don't forget.

[jsstar]

Hi echat11 ,

Still no response so draft defence attached. I’m a little unsure on 7 as no date is mentioned for assignment in the POC. Similarly I’m unsure on the exact section referenced in 11 & 12.

Very grateful for any help in advance! Defence Draft.pdf

[echat11]

Can you copy and paste it on to the thread.

[jsstar]

1.The Defendant received the claim (redacted) from the Civil National Business Centre County Court on 04/07/25.

2.Each and every allegation in the Claimants statement of case is denied unless specifically admitted in this Defence.

3.This claim appears to be for a Credit Card agreement regulated under the Consumer Credit Act 1974.

4.It is admitted that the Defendant has previously entered into an agreement with Onmo Limited for provision of credit.

5.The Claimants statement of case fails to give adequate information to enable me to properly assess my position with regards the claim.

6. The Claimant’s Particulars of Claim fail to state when the agreement was entered into.

7.The Claimants statement of case states that the account was assigned from [Original Creditor] to [Claimant] on [Date]. The Defendant does not recall receiving notice of this assignment.

8. It is denied that Onmo Limited served any Default notice on the Defendant pursuant to s87 Consumer Credit Act 1974. The Claimant is required to prove that a compliant Default Notice was served upon the Defendant. The Claimant is required to prove that the any Default notice relied upon complied with the requirements of s88(4A) Consumer Credit Act 1974 and that the notice was in the prescribed form as required by The Consumer Credit Enforcement Default and Termination Notice Regulations1983.

9. On the 04/07/25 The Defendant sent a request for inspection of documents mentioned in the claimant’s statement of case under Civil Procedure Rule 31.14 to AJJB Law LTD. I requested the Claimant provide copies of the Agreement and Notice of Assignment.

10. AJJB Law LTD has not sent any of these documents to the Defendant.

11. On the 04/07/25 The Defendant sent a formal request for a copy of the original agreement to COEO Securitisation Limited pursuant to section [77 or 78] of the Consumer Credit Act 1974 along with the statutory £1 fee.

12. The Claimant has failed to comply with [s77 (1) / s 78 (1)]Consumer Credit Act 1974 and by virtue of [s77 (4) / s 78 (6)]Consumer Credit Act 1974 cannot enforce the agreement.

13. Under Civil Procedure Rule 16.5 (4) Where the claim includes a money claim, a defendant shall be taken to require that any allegation relating to the amount of money claimed be proved unless he expressly admits the allegation. Therefore, it is expected
that the Claimant be required to prove the allegation that the money is owed as claimed.

14. The Defendant respectfully requests the court orders the Claimants to provide the necessary documentation in order for The Defendant to fully plead his case else the Claim should stand struck out.

15. In the event that the relevant documents are received from the Claimant, the Defendant will then be in a position to amend his defence, and would ask that the Claimants bear the costs of the amendment.

16. It is denied that the Claimant is entitled to the relief as claimed or at all.

[echat11]

Have a read through if you hare happy with it, you can file the Defence with the Court via MCOL.
No. 6 added a comment pertaining to no date.
Aside No. 7 refers to the Limitation Act, I assume it doesn't apply.
I can't check the Statement of Truth as it's missing from your post.


1.The Defendant received the claim (redacted) from the Civil National Business Centre County Court on 01/07/25.

2.Each and every allegation in the Claimants statement of case is denied unless specifically admitted in this Defence.

3.This claim appears to be for a Credit Card agreement regulated under the Consumer Credit Act 1974.

4.It is admitted that the Defendant has previously entered into an agreement with Onmo Limited for provision of credit.

5.The Claimants statement of case fails to give adequate information to enable me to properly assess my position with regards the claim.

6. The Claimant’s Particulars of Claim fail to state when the agreement was entered into.

7.The Claimants statement of case states that the account was assigned from to ONMO, but no date is stated. The Defendant does not recall receiving notice of this assignment.

8. It is denied that Onmo Limited served any Default notice on the Defendant pursuant to s87 Consumer Credit Act 1974. The Claimant is required to prove that a compliant Default Notice was served upon the Defendant. The Claimant is required to prove that the any Default notice relied upon complied with the requirements of s88(4A) Consumer Credit Act 1974 and that the notice was in the prescribed form as required by The Consumer Credit Enforcement Default and Termination Notice Regulations1983.

9. On the 04/07/25 The Defendant sent a request for inspection of documents mentioned in the claimant’s statement of case under Civil Procedure Rule 31.14 to AJJB Law LTD. I requested the Claimant provide copies of the Agreement, Default Notice and Notice of Assignment.

10. AJJB Law LTD has not sent any of these documents to the Defendant.

11. On the 04/07/25 The Defendant sent a formal request for a copy of the original agreement to COEO Securitisation Limited pursuant to section 78 of the Consumer Credit Act 1974 along with the statutory £1 fee.

12. The Claimant has failed to comply with s78 (1) Consumer Credit Act 1974 and by virtue of s78 (6) Consumer Credit Act 1974 cannot enforce the agreement.

13. Under Civil Procedure Rule 16.5 (4) Where the claim includes a money claim, a defendant shall be taken to require that any allegation relating to the amount of money claimed be proved unless he expressly admits the allegation. Therefore, it is expected that the Claimant be required to prove the allegation that the money is owed as claimed.

14. The Defendant respectfully requests the court orders the Claimants to provide the necessary documentation in order for The Defendant to fully plead his case else the Claim should stand struck out.

15. In the event that the relevant documents are received from the Claimant, the Defendant will then be in a position to amend his defence, and would ask that the Claimants bear the costs of the amendment.

16. It is denied that the Claimant is entitled to the relief as claimed or at all.

[jsstar]

Thanks echat11 ,

Apologies the statement didn’t copy across it is as below;

I believe that the facts stated in this defence 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.

Thank you again for your sage advice.

[echat11]

Thanks echat11 ,

Apologies the statement didn’t copy across it is as below;

I believe that the facts stated in this defence 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.

Thank you again for your sage advice.

That's fine.

Update the thread when you get responses to your requests or communications from their solicitors.
It might be an idea to send a SAR to ONMO, make sure you get Proof of Postage.

[jsstar]

Thanks echat11 ,

Defence submitted online. Do I need to send a copy of the defence via post to their solicitors or does MCOL handle everything in that regard.

[echat11]

Thanks echat11 ,

Defence submitted online. Do I need to send a copy of the defence via post to their solicitors or does MCOL handle everything in that regard.

MCOL will do that.

[jsstar]

Hi echat11 ,

Today I have received an ‘annual statement’ from Credit Resource Solutions who appear to be registered to the same address as AJJB Law. The amount on it matches that in the claim so I assume it is related. Text on the letter is as below;

“Annual Statement of Account

Dear XXX

CRS Reference: XXX

Balance: £XXX

On the following page is your annual statement which details all transactions received by Credit Resource

Solutions in relation to the account detailed above.

Statement Period (“the Period”): 01/08/2024 to 31/07/2025

Annual Interest Rate for the Period: 0%

Balance Owing on the first day of the Period: £XXX

Balance Owing on the last day of the Period: £XXX

Should you require further information in relation to the transactions detailed above please do not hesitate to

contact us on 01422 324510 or info@creditresourcesolutions.co.uk. Alternatively you can visit our website

www.mycrs.co.uk where you can speak with one of our agents via Live Chat.

Yours Sincerely,

Credit Resource Solutions”

I’ve not had anything from the court or directly from AJJB - do I need to respond to this? It doesn’t appear to be any of the documents I’ve actually asked for.

Thanks

[echat11]

Hi echat11 ,

Today I have received an ‘annual statement’ from Credit Resource Solutions who appear to be registered to the same address as AJJB Law. The amount on it matches that in the claim so I assume it is related. Text on the letter is as below;

“Annual Statement of Account

Dear XXX

CRS Reference: XXX

Balance: £XXX

On the following page is your annual statement which details all transactions received by Credit Resource

Solutions in relation to the account detailed above.

Statement Period (“the Period”): 01/08/2024 to 31/07/2025

Annual Interest Rate for the Period: 0%

Balance Owing on the first day of the Period: £XXX

Balance Owing on the last day of the Period: £XXX

Should you require further information in relation to the transactions detailed above please do not hesitate to

contact us on 01422 324510 or info@creditresourcesolutions.co.uk. Alternatively you can visit our website

www.mycrs.co.uk where you can speak with one of our agents via Live Chat.

Yours Sincerely,

Credit Resource Solutions”

I’ve not had anything from the court or directly from AJJB - do I need to respond to this? It doesn’t appear to be any of the documents I’ve actually asked for.

Thanks

No you don't, a claim has been lodged, they've chosen Court to resolve the matter.

[jsstar]

Hi echat11 ,

I have now received a Directions Questionnaire (small claims track) from the court. I’m still waiting/have not received any of the documents previously requested. Can you advise the best way to fill this out and can I file it electronically or will I need to post to both court and other party?

thanks