1: I received the claim [Claim Number] from the [Northampton] County Court on [Date Received] 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 mobile agreement not regulated under the Consumer Credit Act 1974. 4: [It is denied] that the Defendant has [previously] entered into [an agreement] with [T-Mobile] for provision of credit. 4: The Claimants statement of case fails to give adequate information to enable me to properly assess my position with regards the claim. 5. The Claimants statement of case states that the account was assigned from [t-Mobile] to [Lowell Portfolio] on [12/08/2016]. The Defendant does not recall receiving notice of this assignment. 6: On the [Date] I sent a request for inspection of documents mentioned in the claimants statement of case under Civil Procedure Rule 31.14 to [Claimant's Solicitor]. I requested the Claimant provide copies of the [Agreement, Default Notice and Notice of Assignment] . 7. [Claimant's Solicitor] has not sent the agreement to me. 8. 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. 9. 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. 10. 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. 11. It is denied that the Claimant is entitled to the relief as claimed or at all.
1: I received the claim xxx from the Northampton County Court on 15 February 2017. 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 mobile agreement not regulated under the Consumer Credit Act 1974. 4: It is denied that the Defendant has previously entered into an agreement with T-Mobile. 4: The Claimants statement of case fails to give adequate information to enable me to properly assess my position with regards the claim. 5. The Claimants statement of case states that the account was assigned from T-Mobile to Lowell Portfolio on 12/08/2016. The Defendant does not recall receiving notice of this assignment. 6: On 4 March 2017 I sent a request for inspection of documents mentioned in the claimants statement of case under Civil Procedure Rule 31.14 to Claimant's Solicitor. I requested the Claimant provide copies of the Agreement and Notice of Assignment. 7. Claimant's Solicitor has not sent the Agreement to me. 8. 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. 9. 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. 10. 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. 11. It is denied that the Claimant is entitled to the relief as claimed or at all.
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