Hoping for some help

[Saul goodman]

Received a claim? Yes

Issue Date: 06 May 25
Have you Acknowledged the Claim?: yes
Total Amount Claimed : 2300
Claimant’s Name:lowell
Solicitors Firm:overdales
Original Creditoraypal
Original Debt paypal credit
Particulars of Claim: It is not statue barred. I have not sent any corresponedence .I am in a lot of debt, but have been ignoring te letters.
i am currently out of work, caring for my wife. i own my home outright

[Saul goodman]

Can someone quickly check my defence please.

• A Credit Card / Catalogue Account is a Running Credit Agreement and falls under section 78.

In the Civil National buisiness centre

Claim No:

LOWELL PORTFOLIO I LTD

Claimant

And



Defendant

DEFENCE

1.The Defendant received the claim [Claim Number] from the County Court on [08/05/2026

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

3.This claim is for a Paypal a Credit Card agreement regulated under the Consumer Credit Act 1974.

4.It is admitted that the Defendant has entered into an agreement with Paypal 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 failed to state when the agreement was entered into/states the agreement w

8.The Claimants statement of case states that the account was assigned from Paypal to Lowell Portfolio i LTD on 24/02/2025. The Defendant does not recall receiving notice of this assignment.

9.It is denied that Paypal 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 Regulations 1983.

10.On the 19/05/2026 Defendant sent a request for inspection of documents mentioned in the claimant’s statement of case under Civil Procedure Rule 31.14 to Overdales Solicitors. I requested the Claimant provide copies of the Agreement, Default Notice and Notice of Assignment.

11. Solicitors has not sent any of these documents to the Defendant.

12.On the 19/05/2026] The Defendant sent a formal request for a copy of the original agreement to Lowell Porfolio inI LTD ursuant to section [78] of the Consumer Credit Act 1974 along with the statutory £1 fee.

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

15.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.

16.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.

17.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.

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

Statement of Truth

[I believe][the (claimant or as may be) believes] that the facts stated in this [name document being verified] are true. I understand] [The (claimant or as may be) understands 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.

Signed ________________________________

Dated ________________________________

[echat11]

Hi SG

Welcome to LB

You really need to provide all the requested information, what does the Particulars of Claim state?


In the Civil National Business Centre

Claim No:

LOWELL PORTFOLIO I LTD

Claimant

And



Defendant

DEFENCE

1.The Defendant received the claim Claim Number from the County Court on 06/05/2026.

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

3.This claim is for a Credit Card agreement regulated under the Consumer Credit Act 1974.

4.It is admitted that the Defendant has entered into an agreement with Paypal 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 failed to state when the agreement was entered into.

7.The Claimants statement of case states that the account was assigned from Paypal to Lowell Portfolio i LTD on 24/02/2025. The Defendant does not recall receiving notice of this assignment.

8.It is denied that Paypal 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 Regulations 1983.

9.On the 19/05/2026 the Defendant sent a request for inspection of documents mentioned in the claimant’s statement of case under Civil Procedure Rule 31.14 to Overdales Solicitors. I requested the Claimant provide copies of the Agreement, Default Notice and Notice of Assignment.

10. The Creditors solicitors has not sent any of these documents to the Defendant.

11.On the 19/05/2026 the Defendant sent a formal request for a copy of the original agreement to Lowell Porfolio International LTD pursuant to section 78 of the Consumer Credit Act 1974 along with the statutory £1 fee.

12.The Claimant has failed to comply with s 78 (1) Consumer Credit Act 1974 and by virtue of 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.

Statement of Truth

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.

Signed ________________________________

Dated ________________________________