Old Lloyds Credit Card

[Sleepysloth7]

I was wondering if anyone could help? Here is my background. I had a credit card with Lloyds bank, opened in 2006. I ended up stopping payments (can’t remember exact date) around 2016/17 due to unemployment and mounting debts. I was never served with a default notice or letter of assignment in writing, however did start receiving letters from Cabot in 2017 saying I owe them money for said credit card. They got Mortimer Clarke involved, eventually I caved and offered a nominal monthly payment, which I stopped paying in 2021.

Fast forward to 2024, Mortimer Clarke started threatening me with court action. They sent a letter before claim. I responded (sent recorded delivery) to Cabot with a CCA request and MC with an SAR request. Both ignored and it went quiet. Until February 2026, when I received a second letter before claim, again to which I responded in the same manor as 2024. Both requests ignored.

Then, on 7th May, I received a claim form from The Civil National Business Centre, stating that Mortimer Clarke are pursing a CCJ.

Last Friday, I submitted an acknowledgment to the court. In the meantime i wrote once again to Cabot with a CCA request and sent MC a 31.14 request. On 18th May, Mortimer Clarke sent me all the alleged paperwork, however the terms and conditions looks cut and pasted and I am questioning its authenticity. Someone else told me that, having looked at what I’ve been sent, “All appears to be a cut and paste and different T&Cs pages from different filling cabinets to make up the pack. Different fonts different font clarity document numbers, legibility etc etc.”

My defence is due Friday 29th May. I’m away most of next week so trying to get something drafted ready to send. I’m now stuck as to what to write. I will attach what I’ve written so far, along with the particulars of claim. I would be grateful for any guidance as this is the first time I’ve had to do this.

[Sleepysloth7]

I would also point out, the paperwork sent to me by MC contained the Default Notice and Letter of Assignmenr, however I NEVER received any of those at the time my account was passed to Cabot.

Which Court have you received the claim from (top right after In The) Civil National Business Centre

1. N1SDT Claim form (03.25)

If possible please scan redact and upload a full page copy of page 1 of the claim form. (not the response page or AOS)
Name of the Claimant ? Cabot Financial (UK) Limited
How many defendant's joint or self ? One (self)
Date of issue :–Give answer here 29th April 2026
Date To File AOS By: 14 days of the day of service (5 days after the issue date) 17/5/2026
Date to File Defence by: 28 days from date of service: 31/5/2026


Particulars of Claim
What is the claim for – the reason they have issued the claim? Please type out their particulars of claim in full (verbatim) less any identifiable data and round the amounts up/down. state how many digits the account number has.. By an agreement between Lloyds Bank & the Defendant on or around 01/09/2006 ('the Agreement') Lloyds Bank agree to issue the Defendant with a credit card. The Defendant failed to make the minimum payment due. The Agreement was terminated following the service of a default notice. The agreement was assigned to the named Claimant. Cabot Credit Management Group Limited, acting as a servicing agent of named Claimant through its Appointed Representative (Cabot Financial (Europe) Limited), has arranged for these proceedings to be issued in the name of the Claimant. THE NAMED CLAIMENT THEREFORE CLAIMS 1. 3317. 65 2. Costs
What is the total value of the claim? £3602.65
Have you received prior notice of a claim being issued pursuant to paragraph 3 of the PAPDC (Pre Action Protocol) ? Yes
Have you changed your address since the time at which the debt referred to in the claim wasallegedly incurred? No
Did you inform the claimant of your change of address? N/A

Is the claim for - a Bank Account (Overdraft) or credit card or loan or catalogue or mobile phone account? Credit Card
When did you enter into the original agreement before or after April 2007 ? Before April 2007 (01/09/2006)
Do you recall how you entered into the agreement...On line /In branch/By post ? In branch
Is the debt showing on your credit reference files (Experian/Equifax /Etc...) ? No
Has the claim been issued by the original creditor or was the account assigned and it is the Debt purchaser who has issued the claim. Debt purchaser
Were you aware the account had been assigned – did you receive a Notice of Assignment? No
Did you receive a Default Notice from the original creditor? No
Have you been receiving statutory notices headed “Notice of Sums in Arrears” or " Notice of Arrears "– at least once a year ? No
Why did you cease payments? Loss of earnings
What was the date of your last payment? 1/3/2021
Was there a dispute with the original creditor that remains unresolved? No
Did you communicate any financial problems to the original creditor and make any attempt to enter into a debt management plan? No

[Sleepysloth7]

I am making a start on my defence, which is due to be submitted Friday 29th May by 4pm. I am making a start on it now as I am away for most of next week. This is what I have so far but I am struggling with what to write regarding the documents recently received from my CRP 31.14 request. Thank you one again for all your help over the past two years, I appreciate it!
Particulars of claim

1. By an agreement between Lloyds Bank & the Defendant on or around 01/09/2006 ('the Agreement') Lloyds Bank agree to issue the Defendant with a credit card.

   2) The Defendant failed to make the minimum payment due.

   3) The Agreement was terminated following the service of a default notice.

4) The agreement was assigned to the named Claimant. Cabot Credit Management Group Limited, acting as a servicing agent of named Claimant through its Appointed Representative (Cabot Financial (Europe) Limited), has arranged for these proceedings to be issued in the name of the Claimant. THE NAMED CLAIMENT THEREFORE CLAIMS 1. 3317. 65 2. Costs.

1. The Defendant contends that the particulars of claim are vague and generic in nature. The Defendant accordingly sets out its case below and relies on Civil Procedure Rules 16.5(3) in relation to any particular allegation to which a specific response has not been made.
2. Paragraph 1 is noted. The Defendant has in the past had a financial arrangement with Lloyds but does not recall the precise details. The Claimant has failed to provide any reference number by which to identify 'the Agreement' within their Particulars of Claim.
3. Paragraph 2 and 3 are noted. The Defendant maintains that a default notice was never received. The Claimant is put to strict proof that a default notice was issued by Lloyds and received by the Defendant.
4. On the 8th May 2026 (sent by recorded delivery) I requested information pertaining to this claim by way of a CPR 31.14 request. Mortimer Clarke wrote to me, letter dated 18th May acknowledging my request and sent me an alleged copy of 1) Credit Card agreement (which was in the form of a "Classic visa Credit Card Application Form) with Terms and Conditions 2) Current Credit Card Terms and Conditions; and 3)Signed Statement of the account on behalf of Cabot this is the one I'm not sure what to write?
5. Paragraph 4 is noted. It is denied with regards to the Defendant owing any monies to the Claimant, and the Claimant is put to strict proof to: Show how the Claimant has the legal right, either under statute or equity to issue a claim.

Also, do I put in the defence that I sent a CCA request on 19/6/2024 and 3/3/2026, both of which were ignored by the Claimant?

[echat11]

Hi Sleepysloth7

Welcome to LB

You might have done some of these steps. In your Defence all you are addressing is the Particular of Claims. If so go straight to e), amend as necessary, then copy and paste back to this thread, without personal details. I can check it, then you can file it via MCOL, then you can rest easy that it's filed with the Court.


a) First Acknowledge the Claim, you can do this online via MCOL, this will give you 28 days (plus 5 days postal) in total to work on your defence

https://legalbeagles.info/library/gu...ledge-a-claim/

b) Send a SAR request to Original Creditor, they have 30 days to provide all the data they hold on the account. Make sure you get Proof of Postage.

https://legalbeagles.info/library/gu...ccess-request/

c) Send a CCA request to the Claimant, they have 12 days to provide a copy of the original agreement. Make sure you get Proof of Postage.
https://legalbeagles.info/library/gu...etter-example/

d) Send a CPR 31.14 request to their solicitors, they have 7 days to provide all the documents they are relying on to make the claim against you, again get Proof of Postage. - You've done this.

https://legalbeagles.info/library/gu...-of-documents/

e) This is an example Defence, start looking at it, don't fill or file it with the Court or their solicitors yet.

https://legalbeagles.info/library/gu...-court-claims/

Don't speak to creditors, solicitors etc over the phone, everything in writing. Keep on top of this, especially dates for filing defence etc.

[Sleepysloth7]

I’ve done all of this, and now I have submitted my defence by Friday of this week. I’ve started to write my defence above but stuck on what to write with regards to the documents they e sent, which look like a cut and paste job and not the originals

[Sleepysloth7]

Sorry, I meant to have written that I have until this Friday to submit my defence.

[echat11]

I’ve done all of this, and now I have submitted my defence by Friday of this week. I’ve started to write my defence above but stuck on what to write with regards to the documents they e sent, which look like a cut and paste job and not the originals

You aren't addressing the 'cut and paste' issue at this stage, that will be done later.

As stated previously, all you are stating in your Defence at this stage is responding to their Particulars of Claim.

You aren't getting into the detail of your Defence.

e) This is an example Defence, start looking at it, don't fill or file it with the Court or their solicitors yet.

https://legalbeagles.info/library/gu...-court-claims/