Advice Needed on Witness Statement

[Tallulahtwinkle4477]

Hi
I have to submit my witness statement against a claimant who is a debt collector for a claim over an alleged debt, by this Friday. Please could someone advise on the following, I have removed any of mine or their details.

Please could someone take a quick look and advise? any tips appreciated!
I will not be attending court as my director and several other members of staff are on annual leave, I will be writing to the court 7 days prior to the case to advise them of this.

thanks


Case Name: XXXXXXXXXXXXXXXXXXXXXXX
Case Number: XXXXXXXXX

I, Miss xxxxx of (addresswill go here) wish to submit my witness statement in defence for the abovecase.

a) Ireceived a letter from (claimant) and also (claimants solicitors) dated 17^thMarch 2016.
These letters detailed that (claimantssolicitors) are now pursuing an alleged debt of £xxx.xx against me. In turn Iresponded with a letter dated 11^th April requesting allcommunication to be in the written form and requesting verification of theclaim from Claimant along with the true and certified copies of the Deed ofAssignment and the Deed of Novation.
Please see Exhibit 1 – 4 pages.

b) Ireceived a letter from Claimants Solicitors dated 26^th April 2016 stating they would not be sending me the Deed of Assignment as it wasconfidential and contained information which I am not entitled to see.
Please see Exhibit 2 – 1 page.

c) Iresponded with a letter dated 1^st May 2016 repeating my request sothat Claimant could validate their claim.
Please see Exhibit 3 – 2 pages.

d) Afterno further correspondence from Claimant I sent a notice of Estoppel 30 daysafter my second letter, exhibit 3.
Please see Exhibit 4 – 2 pages.

e) Ireceived, from Claimants Solicitors, aletter dated xxxxx 2016, including acopy statement which proves absolutely nothing with regards to me owing theirclient any monies. The statement is a typed up spreadsheet which has beenprinted out.
The letter noted that a copyof the agreement would follow.
Please see Exhibit 5 – 4 pages.

f) Ireceived a letter from Claimants Solicitors, dated xxxxx 2016, This included anunsigned letter, allegedly from alleged original creditors name , an excel typeapplication form, and a further copy of the already sent spreadsheet typestatement.This did not include any ofthe original documents that I had requested for Claimant to validate theirclaim.
Please see Exhibit 6 – 6 pages.

g) LetterReceived from County Court Business Centre dated 19^th July 2016.

h) Isent a CPR 18 Preliminary request to claimants Solicitors, on the date of 26^thJuly 2016. Please see Exhibit 7 – 2 pagesplus a proof of posting receipt.

i) Isent a letter to claimant, dated 26^th July 2016, along with a postalorder for £1.00 requesting a credit agreement. This information was to besupplied within 12 working days. Please see Exhibit 8 – 2 pages plus copyreceipts.

j) Letterdated 6^th August 2016 received from Claimants Solicitors indicating theaccount is on hold until a copy of the original credit agreement has beenreceived – Please see Exhibit 9 – 1 page.

k) LetterReceived dated 15th August 2016 acknowledging receipt of defence online –Letter is from HN Courts and Tribunals.

l) Letterreceived from Claimants Solicitors dated 5^th October 2016 withcopies of previously received documents (unsigned letter, excel typeapplication form and excel typestatement as per 27^th June 2016. ) This does not include a copy ofthe original credit agreement.Pleasesee Exhibit 10 – 6 pages.

m) Letterreceived from Claimants Solicitors dated 19^th October 2016 asking meto call and make payment. I ignore this as they have previously failed to sendme the documents needed to validate their pursuing of this alleged debt againstme.


I believe the facts stated inthis witness statement are true.

Signed:






XXXXXXXXXXXXXXXXXXXXX

Dated: XXXXXXXXXXXX