Help please - Litigant in person TOLATA Claim

[Johns2024]

I'm hoping someone can help. I am well into proceedings for a TOLATA claim with my ex-partner, both of us are unrepresented.
We purchased a house as beneficial joint tenants, I moved out 5 years ago as we separated. We have no children and not married. They have refused to sell or buy out for the past 5 years so earlier this year i began proceedings under TOLATA. 2 years ago they changed the title register to tenants in common. No deed of trust or declaration of trust has ever been drawn up.
We have a had a directions hearing and statements exchanged and have received directions with a view to a trial next year. Their statement is basically a personal attack and repeatedly states they have never objected to selling the house (I have several emails to the contrary) but instead only talks about contributions since I moved out. Since moving out I have not paid the mortgage as I cannot support 2 homes, I believe the mortgage has been paid by her new partner who moved in 2 months after I moved out.
Their statement consists of malicious allegations which I have documents to disprove. They have failed to provide standard disclosure of documents by list on form N265 or a disclosure statement which was due 4 weeks ago, instead I have received copies various versions of copies of documents relating to the house but nothing to show that they have made any contributions since I moved out or to argue the selling of the property. They has also submitted a fabricated invoice for £21,000 of 'maintenance work' with the company name redacted (they're partner is a builder so its not rocket science) I have served an N266 Notice to Admit Facts regrading if the invoice is forged and admit that her partner's company is behind the redaction on the invoice but they have refused to respond on the N266.
My question is, with directions being ignored, fabricated documents being disclosed, malicious allegations and irrelevant allegations being made in the statement alongside not actually protesting against the sale of the house and only focusing on who gets what when it is sold.....do I need to submit an N244 to apply to strike out their defence or apply for a summary judgement? I'm just not sure if I can apply for a summary judgement when a residential premises is involved.

Thanks in advance

[atticus]

I doubt that either of those tactics will work.

You need to focus on the essentials of the case, the questions the judge will have to decide. Usually these are whether and how the house is to be marketed for sale and the respective shares in the equity.

Unfortunately, in litigation it helps to have a thick skin.

[Johns2024]

Atticus thank you for replying. Does it not matter that directions are being ignored and documents are being fabricated which if left unchallenged will undoubtedly affect my case adversely?

[atticus]

Of course it matters. You need to draw these things to the attention of the court. If you challenge the authenticity of documents you need to explain your reasons - can you demonstrate the forgery?

[Johns2024]

I can absolutely demonstrate the forgery and prove it is completely fabricated. I will make sure the court is aware of all of these things

[atticus]

Be aware of CPR 32.19: https://www.justice.gov.uk/courts/pr...s/part32#32.19

If you do not admit the authenticity of a document disclosed by the other party give notice immediately.

[Johns2024]

Would an N244 be the best form to give notice of this?

[Pezza54]

Form N268 is used by a party in a civil court case to formally request that documents are proven or presented as evidence at trial

[Johns2024]

Thank you very much. One last question, is there a complete list of forms somewhere online which has all forms that can be served on another party?

[atticus]

https://www.gov.uk/government/collec...tribunal-forms