Civil Enforcement LTD Private Car Park 4 Year Old Court Claim Letter Received.

georgeireland

Coupon-mad said:

That's fine as the para 3 to add to our template defence.

Okay, how much of the other 23 paragraph do you recommend I edit? Or should I just leave it as template to be safe?

Thanks!

georgeireland

Fruitcake said:

Perhaps you could change this, 

"It is questionable whether the landowner even wishes to pursue this claim."

To this,

"It is averred that the landowner does not wish the claimant to pursue this claim, and the claimant is put to strict proof that the contrary is true."

The only problem would be if the landowner wanted the case to proceed, but from what you have said, this is not the case.

The only issue I have is that the landowner is completely unreachable so I'm hesitant to specify whether he is or not wanting to proceed. It's incredibly doubtful given the kind of person he is (nice) but I can't say for certain. 

Umkomaas

But it's the claimant's case to prove. You are 'averring', not specifying. Perfectly normal in a defence. Let the claimant prove that the landowner definitely wants 'blood'!

georgeireland

Umkomaas said:

But it's the claimant's case to prove. You are 'averring', not specifying. Perfectly normal in a defence. Let the claimant prove that the landowner definitely wants 'blood'!

Ah right, that makes a lot more sense. Thanks!

Le_Kirk

georgeireland said:

Coupon-mad said:

That's fine as the para 3 to add to our template defence.

Okay, how much of the other 23 paragraph do you recommend I edit? Or should I just leave it as template to be safe?

Thanks!

You don't edit any of the other paragraphs in the template defence, just add in your paragraph #3.  What have you put as your paragraph #2?

georgeireland

Le_Kirk said:

georgeireland said:

Coupon-mad said:

That's fine as the para 3 to add to our template defence.

Okay, how much of the other 23 paragraph do you recommend I edit? Or should I just leave it as template to be safe?

Thanks!

You don't edit any of the other paragraphs in the template defence, just add in your paragraph #3.  What have you put as your paragraph #2?

I've put it as a simple:

"2. It is admitted that the Defendant was the registered keeper and driver of the vehicle in question but liability is denied. "

Fruitcake

georgeireland said:

Le_Kirk said:

georgeireland said:

Coupon-mad said:

That's fine as the para 3 to add to our template defence.

Okay, how much of the other 23 paragraph do you recommend I edit? Or should I just leave it as template to be safe?

Thanks!

You don't edit any of the other paragraphs in the template defence, just add in your paragraph #3.  What have you put as your paragraph #2?

I've put it as a simple:

"2. It is admitted that the Defendant was the registered keeper and driver of the vehicle in question but liability is denied. "

That's fine.

georgeireland

Magic! I'll be sending it tomorrow at about 9:30 AM with the email looking like this: Title will be "Claim No: ABCDEF123 DEFENCE" to the address CCBCAQ@Justice.gov.uk

 

URGENT! RE: Claim No: ABCDEF123 – Please find my Defence attached,

The claimant’s legal team can be contacted via the email address: Legal3@ce-service.co.uk

 

Please send acknowledgement back to me via this email. Thank you.

Le_Kirk

Paragraph #2 is good, e-mail address for CCBC is good as is that for CE.  Also found this address useful for CE: -
office@ce-service.co.uk

georgeireland

Wonderful, it's been sent off now. Received an automatic email back. For now I will look at the questionnaire section whilst waiting for the response. 
Thank you to everyone again!