Help with wording of POC please

[CuriousM]

Hello,
I am in the process of starting a Court Claim via MCOL to be reimbursed for the cost of goods which were bought for the ongoing operations of a business but not fully paid for by the business owner. I am struggling with getting the wording of the POC correct and complete while fitting it into 1080 characters. I could really use some advice please.

My draft of the POC is as follows:

1. Shortly before XX/XX/XXXX the Defendant, at all material times the Leaseholder and proprietor of XXXX, entered into an oral contract with the Claimant, the former XXXX of XXXX, to reimburse the Claimant the sum of £XXXX (later reduced to £YYYY) for the purchase cost of equipment and consumables provided by the Claimant for use in the Defendant’s ongoing business operations.
2. Written terms of contract were provided to the Defendant on XX/XX/XXXX.
3. Express condition of contract: Reimbursement to be made by initial lump sum of £XXXX followed by monthly instalments of at least £XXX commencing XX/XX/XXXX.
4. Initial repayment of £XXXX made on XX/XX/XXXX and first instalment of £XXX on XX/XX/XXXX.
5. Despite repeated requests both orally and written no further payments were forthcoming.
6. Given paragraphs 4 and 5, the Defendant is in breach of the terms of the contract.
7. The Claimant claims: (a) Payment of outstanding sum of £ZZZZ; (b) Interest pursuant to S.69 of the County Court Act 1984; (c) Court fee of £185.

The reason I stated "£XXXX (later reduced to £YYYY)" is because the evidence of the original agreement shows the sum of £XXXX but an email at a later date states a reduced amount of £YYYY with the explanation of certain costs being excluded.

Some questions I have:
a.) Is all of the above wording sufficient? Are there any other points I need to make, bearing in mind I'm at 1075 characters already?
b.) In Paragraph 7 do I need to list a specific interest amount (with calculations) or can I leave the determination of that up to the Court?
c.) If leaving the interest amount up to the Court, on the MCOL online form do I enter only the outstanding sum of £ZZZZ as the amount to be claimed? Or must this amount include interest?

Any help greatly appreciated!

[R0b]

Why don't you just shorten it and then tick the box that says you will provide detailed particulars within 14 days of the claim form being served? The MCOL box is severely limited so you can't get everything you need in there unless it is a very straight forward.

If there's written terms that were accepted and there is a term that was breached you need to reference the terms that were breached and what you are relying.

[CuriousM]

Hi Rob, thank you for your prompt advice.

I was hoping to cover everything in the MCOL form but yes it does make sense to send off more detailed particulars, I will do that.

However, I am still unsure about whether to include a calculated interest amount (e.g., 8% per annum for XX days) or leave it up to the Court to decide, as per my questions (b.) and (c.) in my original post. Can you please advise?

One thing I forgot to mention was that the Defendant agreed verbally to the contract and was sent the written contract but never actually signed it. However, I am hoping the fact that he reimbursed the initial lump sum and the first monthly instalment (albeit about 5 months late) shows that he was in agreement with the terms. Will this hurt my case?

[R0b]

Just whack in the interest at 8%. If the court thinks the 8% is too much then it will at it's discretion, reduce the interest rate.

On MCOL there should be an option for calculating interest, although I can't quite remember what it says it will ask you some questions and then actually incorporate into the POC (if you are keeping it within the limited text box) and set out the daily rate. But if you are going to send the detailed POC you don't mention it on MCOL and instead insert it in the detailed POC at the end.

You will need to explain the bit about written terms. Were they already written and then presented to the builder who accepted them and then you sent a copy out? or did you verbally agree the terms and then write what was agreed and sent it in a written format?

[CuriousM]

You will need to explain the bit about written terms. Were they already written and then presented to the builder who accepted them and then you sent a copy out? or did you verbally agree the terms and then write what was agreed and sent it in a written format?

It was the latter -- the terms were discussed and verbally agreed, then I wrote up the agreement and sent it to the owner. There was no mention (either verbally or written) of him ever disputing the terms, he simply avoided paying the outstanding amount.