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Re: Arrow & Court Papers What to do?
IN THE XXXXXX COUNTY COURT
CLAIM BUMBER XXXXX
BETWEEN
1. This claim is neither admitted nor denied with regards to the Defendant entering in to an Agreement or contract referred to in the Particulars of Claim ('the Agreement' or contract) the Claimant has yet to disclose any Agreement or contract as to the defendants CPR 31.14 Request. The claim fails to disclose any cause of action and is extremely vague in nature. The claim fails to deal with the basic rules of CPR, even allowing the constraints of a bulk issuer.
2. The defendant has absolutely no knowledge of any debt, and despite asking for proof a debt exists nothing has been forthcoming.
3. No documents supporting this claim in the particulars have been attached despite a request under CPR 31.14, and as a result of this, the defendant is unable to plead in defence to this claim.
4. Without clarification of the claimants claim, the defendant is extremely disadvantaged and the claimants claim appers to be without merit. The defendant asks to to be allowed to submit a complete defence should the claimant provide copies of the original document he will rely on.
5. The particulars of claim are denied with regards to the Defendant owing any monies to the Claimant and the Claimant is put to strict proof to:
(a) show how the Defendant has entered into an agreement or contract with the Claimant; and
(b) show how the Defendant has reached the amount claimed for; and
(c) show how the Claimant has the legal right, either under statute or equity to issue a claim;
6. As per Civil Procedure Rule 16.5(4), it is expected that the Claimant prove the allegation that the money is owed.
7. Furthermore, if the Claimant is an assignee of a debt, it is denied that the Claimant has the right to lay a claim due to contraventions of Section 136 and 196 of the Law of Property Act 1925 and Section 82 (a) of the Consumer Credit Act 1974.
8. The claimant has failed to comply with sections 111 AND 1V of the pre action conduct "practice directions"
9. By reason of the facts and matters set out above, it is denied that the Claimant is entitled to the relief claimed or any relief.
10. For advoidance of doubt, the defendant is unable to plead effectively or at all to the particulars of claim
Statement ofTruth
I believe that the facts stated in this Defence of claim to be true.
Dated this 18th October 2012.
now remember to fill your name in as defendant
and what county court (in the xxx county court)
and case number
thanks ALHAM, i do tend to get carried away and forget the obvious
IN THE XXXXXX COUNTY COURT
CLAIM BUMBER XXXXX
BETWEEN
ARROW GLOBAL
CLAIMANT
V
LIZZ1
LIZZ1
DEFENDANT
DEFENCE
2. The defendant has absolutely no knowledge of any debt, and despite asking for proof a debt exists nothing has been forthcoming.
3. No documents supporting this claim in the particulars have been attached despite a request under CPR 31.14, and as a result of this, the defendant is unable to plead in defence to this claim.
4. Without clarification of the claimants claim, the defendant is extremely disadvantaged and the claimants claim appers to be without merit. The defendant asks to to be allowed to submit a complete defence should the claimant provide copies of the original document he will rely on.
5. The particulars of claim are denied with regards to the Defendant owing any monies to the Claimant and the Claimant is put to strict proof to:
(a) show how the Defendant has entered into an agreement or contract with the Claimant; and
(b) show how the Defendant has reached the amount claimed for; and
(c) show how the Claimant has the legal right, either under statute or equity to issue a claim;
6. As per Civil Procedure Rule 16.5(4), it is expected that the Claimant prove the allegation that the money is owed.
7. Furthermore, if the Claimant is an assignee of a debt, it is denied that the Claimant has the right to lay a claim due to contraventions of Section 136 and 196 of the Law of Property Act 1925 and Section 82 (a) of the Consumer Credit Act 1974.
8. The claimant has failed to comply with sections 111 AND 1V of the pre action conduct "practice directions"
9. By reason of the facts and matters set out above, it is denied that the Claimant is entitled to the relief claimed or any relief.
10. For advoidance of doubt, the defendant is unable to plead effectively or at all to the particulars of claim
Statement ofTruth
I believe that the facts stated in this Defence of claim to be true.
Dated this 18th October 2012.
now remember to fill your name in as defendant
and what county court (in the xxx county court)
and case number
thanks ALHAM, i do tend to get carried away and forget the obvious
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