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That post above is one big wall of text, I would suggest you edit it into paragraphs than just doing a copy and paste job to make easier reading.
I've only skimmed it but I agree with Des that your reasons for claim is more like a witness statement than how they are in breach and what legal right(s) you are relying on. The Defendant's point about reserving the right to serve an amended defence is just crap, because they need permission of the court to do that, though it may be reasonable on if you try to introduce anything substantial and at your expense.
You could make an application to amend your claim at the cost of £255, or you could serve a reply to the defence and simply make it clear in the first few paragraphs what the cause of action e.g. breach of the Consumer Rights Act 2015, negligence etc. It might mitigate the issue their objecting to, but doesn't stop them or the court from striking it out for non-compliance, though usually you should be offered a right to remedy the problem as a strike out is a draconian measure.
I've only skimmed it but I agree with Des that your reasons for claim is more like a witness statement than how they are in breach and what legal right(s) you are relying on. The Defendant's point about reserving the right to serve an amended defence is just crap, because they need permission of the court to do that, though it may be reasonable on if you try to introduce anything substantial and at your expense.
You could make an application to amend your claim at the cost of £255, or you could serve a reply to the defence and simply make it clear in the first few paragraphs what the cause of action e.g. breach of the Consumer Rights Act 2015, negligence etc. It might mitigate the issue their objecting to, but doesn't stop them or the court from striking it out for non-compliance, though usually you should be offered a right to remedy the problem as a strike out is a draconian measure.
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