CCJ set aside of CEL claim

Coupon-mad

All paragraphs need a number.

All pages need a number.

Your exhibit numbers are strange, as they don't flow in order. Why aren't they just your initials1, your intials2, etc., attached as PDFs in the same order that you mention them in the WS narrative?

Initial findings from the Court of Appeal hearing are provided for the court’s reference (Exhibits C and D).

Nope. The case is completed so you aren't showing 'initial findings'. You should be showing the final transcript of VCS v Carr.

Also Chan & Akande transcripts to support a strike-out request that you must voice.

Did you already exhibit proof of where you lived, with your first WS?

1505grandad

The Statement of Truth is not the correct one

Le_Kirk

I confirm that the contents of this statement are true to the best of my knowledge, information and belief.1.Purpose of this Supplementary Statement

1.Purpose of this Supplementary Statement is to addresses the following key issues:

This supplementary statement

You could tidy this up as above

Sumsum12

Hi , Thank you all for taking the time to read my WS statements and point out corrections.

Coupon-mad, thank you for highlighting that issue. After rewriting the document many times and doing a lot of copy and paste, I seem to have missed those details. I will make the necessary changes.

Regarding the transcript of Chan & Akande, it was submitted last year together with my skeleton argument, along with the bills, council tax documents, voter registration, and the bank remortgage letter. However, the Land Registry document was not included at that time, so I am now including it with my WS to show that the property was registered long before the PCN and the claim.

Unfortunately, the evidence included in my initial WS was not properly organised into exhibits or clearly referenced, so I am unable to refer to it effectively. At that time, I did not know how to prepare a proper WS and had already submitted it before I found this forum. For this reason, I am planning to copy all the documents, organise them properly, and provide a clear bundle for the judge and CEL so that they do not have to search through the paperwork and have clear references because I am not sure whether the court will accept the same evidence being included again in my SWS, as it may be considered a duplicate.

All the evidence I previously submitted showed only when I moved into my current home, but it did not show when I moved out of my old addresses . I also did not provide a copy of the tenancy agreement for the property where I stayed temporarily because the Land Registry record of my current house shows that it was registered well before the PCN, the claim, and the court proceedings, and my driving licence was also updated with this address. Therefore, my current address was already known and didn't think it is necessary to submit it .

1505grandad, thank you I will correct it and Le_Kirk I will follow your advice.thank you

One more question: how long should SWS be, and is there a limit on the number of pages including evidence I can submit for it to be accepted by the court?

Coupon-mad

Thing is, WS sent to court by email are not generally allowed to exceed 50 sides of A4 and your first one is probably close to that already?

Don't repeat your previous exhibits.

Sumsum12

Hi again , I just called the court and was told that the Supplementary Witness Statement (SWS) I sent has not yet been uploaded to the system.

They said that it may take around 10–15 days due to a backlog.

I explained that my hearing is next week, which means the judge may not have access to the document before the hearing.

The court staff member suggested that I call again next week to check whether it has been uploaded.

I know that it was my responsibility to send the document earlier, but I am worried about what happens if the judge has not received it in time.

If the SWS has not been uploaded before the hearing, would I be able to provide a printed copy to the judge at the hearing, or is there a risk that it may not be accepted?

Also my original witness statement and skeleton argument together about 50 pages, and with the Supplementary Witness Statement the bundle would be around 68 pages in total. Would the court normally refuse to consider additional pages at this stage?

I have also not yet received confirmation that the Claimant has received my SWS email. If the document has not been formally added to the court file, would the Claimant agree to to be included and read in the hearing?

Finally, if the transcript has not been formally included in the bundle, am I still allowed to refer to the Court of Appeal decision in VCS Ltd v Carr during the hearing and show the additional evidence?

Also do I need to refer to all of the additional supporting case laws mentioned in my Ws/ Skeleton argument, or is it sufficient to focus on the key evidence such as Vehicle Control Services Ltd v Carr, CPMS Ltd v Akande, and Civil Enforcement Ltd v Chan when presenting my defence?

It Is difficult to remember all of them or talk about them in this short time.

Would it be acceptable for me to read from my notes during the hearing, rather than speaking entirely from memory, so that I can present my arguments clearly and avoid making mistakes?

tksnota

Hi,

I have CCJs less than 2 years under my name and just recently got a PCN

I believe CCJs will last longer on my credit file compared with the PCN

Is it advisable to pay the PCN or just wait for it to drop from my file?

//tksnota

Coupon-mad

https://forums.moneysavingexpert.com/discussion/comment/81921859#Comment_81921859

Please start a thread.

This one is only for @Sumsum12

Coupon-mad

Also my original witness statement and skeleton argument together about 50 pages, and with the Supplementary Witness Statement the bundle would be around 68 pages in total. Would the court normally refuse to consider additional pages at this stage?

Probably.

So over the weekend, if I were you, I'd pop a full printed copy of everything in the court mailbox on site, in a sturdy large envelope marked:

URGENT FOR CLAIM XXXXX Hearing date xx/xx/2026

Sumsum12

Thank you Coupon-mad,

If submitting a hard copy bundle would help ensure that the judge has access to the documents for review before the hearing, and would not cause duplication or confusion for court staff, I would be happy to provide one.

By "all " you mean providing the full bundle, including the Witness Statement, Skeleton Argument, Supplementary Witness Statement, and supporting evidence.

Would it also be necessary for me to bring the original evidence documents( Land Registry, mortgage approval, driving licence..etc)to the hearing, or would the copies already submitted be sufficient?

If I do deliver a hard copy bundle to the court, should I include a short covering letter explaining the reason for providing the documents in hard copy? For example, stating that the documents were previously emailed on xxx, but are now being supplied in hard copy due to the volume of pages (over 50 pages) to assist the court as well recieve them sooner.

As mentioned previously, my original witness statement bundle was not fully page-numbered. Would it be acceptable for me to now include a single page table of contents, listing the sections and evidence, and to number the pages throughout the bundle?

Additionaly, What is the prefered structure for presenting the physical bundle to the court. For example, should the documents be arranged as follows:

Option 1:
1)Skeleton Argument (including authorities such as CPMS Ltd v Akande and Civil Enforcement Ltd v Chan)
2)Transcript of Vehicle Control Services Ltd v Carr
3)Supplementary Witness Statement
4)Original Witness Statement and evidence

Or alternatively:

Option 2:
1)Skeleton Argument with supporting authorities
2)Supplementary Witness Statement (with the VCS v Carr authority that is included in its exibit)
3)Original Witness Statement and evidence

Also the instructions in Notice of hearing application state that bundles must be submitted by email no less than 5 days and no more than 10 days before the hearing. Does this timeframe include weekend days?

If weekends are included, then the documents were emailed 8 days before the hearing, which means they were submitted within the required timeframe. In that case, the delay in the documents appearing on the court file would simply be due to the court’s internal processing, rather than late submission and judge might accept to read it along my WS.

However, the instructions also mention that hard copy bundles should be provided at least 5 clear days before the hearing. If I were to deliver a hard copy today, the court would receive it only 4 days before the hearing(next Friday), which appears to fall outside that requirement.

I’m a bit disappointed in myself for not reviewing the instructions earlier and leaving this until now. I’m hoping that the judge will allow me, during the hearing, to provide the transcript of Vehicle Control Services Ltd v Carr along with the additional evidence and allow me to address the relevant points in my hearing.