County Court Claim from CEL

Coupon-mad

It's quite wordy but you do appear to cover the bases. The only thing I would add is that I think the stupid charge had been inflated from (presumably) £100 to well over three hundred pounds! So you need to charge this to object to the other add-ons (except the court fees) not just £50, they've added silly money plucked out of thin air:

The Claim includes a sum of £50, described as ‘Legal Representative’s costs’. The Claimant is put to strict proof of all his assertions.

Barbie2017

Ok here is my point 9 now (please let me know if now Ok to sumbit or if you think of any more changes):

9. The Claimant’s Solicitors are serial abusers of the Court process; the Claimant is known to be a serial litigant, issuing up to 1,000 similar claims on a weekly basis.

a) This is a speculative serial litigant, issuing a large number of identical 'draft particulars'. The badly mail-merged documents contain very little information.
b) The Claim includes a sum of £50, described as ‘Legal Representative’s costs’. Given the Claimant uses a fully automated, bulk processing service, requiring no intervention from a Solicitor often generating up to £50,000 of income they are put to strict proof to show how this cost has been incurred. The Claimant is put to strict proof of all his assertions.
c) The Claim is in excess of £300. Without information to the contrary, I believe the original amount for a Parking Charge would have been £100 or less. Given the Claimant uses a fully automated, bulk processing service, I also object to all additional charges associated with this Claim and the Claimant is put to strict proof of all his assertions.
[FONT=&quot]d) In the above circumstances, I respectfully ask that the Court dismiss the claim.[/FONT]

Coupon-mad

Good one, I think you have done what you need to at this stage and need to just be aware from bargepole's post in the NEWBIES thread (under 'Small Claim?') about the other forms that will follow and what you must do and by when.

Barbie2017

OK, fingers crossed, will submit now! Will keep this thread updated as to how I get on as well!

Yes I have read Bargepole's advice and am expecting more paperwork and deadlines once I hav sent this defence. Bargepole does recommend to post defence instead of using online (due to the numbering formatting etc.) however I'm going to try online and see how I get on (will report back if I do different).

here is the link to Bargepole's great advice for anyone reading my thread;

https://forums.moneysavingexpert.com/discussion/5546325

Thanks once agan to Coupon-mad and all that have contributed, fingers crossed I have good news in the near future.

Cheers

Barbs

Barbie2017

Had trouble on MCOL, not enough lines of text to fit my defence (essay)! Only allowed 122 lines of text.

Therefore going to print and post. (presume this is OK even though I started the process and sent my AOS through MCOL)?

Cheers

Barbs

Coupon-mad

Bargepole suggests that and tells you how to set it out, right down to the font size! Never put the defence in on MCOL.

Barbie2017

OK, it transpired that I have to do it this way anyway. And yes followed his advice on fonts etc. etc.

Address sending to is:

County Court Business Centre
4th Floor, St Katharine's House
21-27 St. Katharine's Street
Northampton
NN1 2LH

is that correct and OK, do I have to send recorded so it's signed for?

Cheers

Barbs

Coupon-mad

That address is correct and you could send it recorded.

Redx

once done you could probably email it as a pfdf to the court and ask them to add it as a digital addition to the file , quoting the case number etc , then conform with them its been added (so they get an electronic version plus an identical paper version in the post

yes , send it recorded if you want confirmation of its receipt

Barbie2017

Thanks all.

I posted my Defence yesterday, delivery is recorded and due there today. Emailed ccbc@hmcts.gsi.gov.uk with a digital version just now.

Will keep you informed.

Barbs