Defence help please

[Bounty]

I have posted on my original thread but had no reply, I am worried as my defence needs to be sent asap as im running out of time! is there someone that could please help me with this.

[Bounty]

Re: Defence help please

1. I received the claim (C4HK8A3V) from the Northampton county court on 26 August 2016
   
2. Each and every allegation in the claimants statement is denied unless specifically admitted in this defence.
   
3. The claim appears to be for a catalogue account agreement regulated under the consumer credit act 1974.
   
4. the claimants statement of case fails to give adequate information to enable me to properly assess my position with regards to the claim
   
5. The particulars of the claim fail to state when the agreement was entered into
   
6. The claimants statement of case states that the account was assigned from shop direct to Lowell Portfolio l LTD on 19/02/2016. The defendant does not recall receiving notice of this assignment.
   
7. It is denied that Shop Direct 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.
   
8. On the date 30/08/2016 I sent a request for inspection of documents mentioned in the claimants statement of case under civil procedure Rule 31.14 to Lowell Solicitors limited . I requested the claimant to provide copies of the Agreement, Default Notice and Notice of Assignment.
   
9. Lowell solicitors limited have not sent any of these documents to me.
   
10. On 30/08/2016 I sent a formal request for a copy of the original agreement to Lowell Portfolio l LTD pursuant to section 78 of the consumer credit Act 1974 along with the statutory £1 fee.
    
11. The claimant has failed to comply with section 78 (1) consumer credit Act 1974 and by virtue of S78 (6) consumer credit Act 1974 cannot enforce the agreement.
    
12. 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 claim 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.
    
13. I request the court orders the claimants to provide the necessary documentation in order for me to fully plead my case else the claim should stand struck out.
    
14. In the event that the relevant documents are received from the claimants I will then be in a position to amend my defence, and would ask that the claimants bear the costs of the amendment.
    
15. It is denied that the claimant is entitled to the relief as claimed or at all.
    Statement of Truth
    

The Defendantbelieves that the facts stated in this defence are true

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I'm going to send this and hope its
correct!