County Court Claim AM Parking Services Ltd

Here is my covering letter to the court (should I have bolded my two requests like this?):

[FONT=&quot]Dear Sir/Madame,[/FONT]
[FONT=&quot]Please find enclosed my completed N180 Directions Questionnaire form.[/FONT]
[FONT=&quot]I have also received the Claimants’ N180 form and understand that they have lodged a Request for Special Direction by asking for the claim to be heard “on the papers.” I would like to lodge my formal objection to this Request for Special Direction.[/FONT]
[FONT=&quot]As an unrepresented defendant, I require a hearing at my local Court because the Claimant’s legal representatives have followed their usual path of ‘roboclaims’ by:[/FONT]
[FONT=&quot]1) [/FONT][FONT=&quot]No clear and concise Particulars of Claim. The Claimant’s legal representatives are known to withhold any contract/facts until the last minute (often ambushing Defendants late with paperwork never shown earlier). This potentially causes me at an extreme disadvantage if this cases is heard 'on papers' because based on the routinely sparse information provided to me so far, it has been almost impossible to put together a detailed defence. I respectfully request that, in the event that the claim is not struck out due to the reasons in this letter, the court exercises its discretion to allow a more detailed defence to be submitted without cost, should Claimants finally produce late evidence.[/FONT]
[FONT=&quot]2) [/FONT][FONT=&quot]The particulars of claim do not meet the requirements of Practice Direction 16 7.5 as there is nothing which specifies how the terms were breached. Indeed, the particulars of the claim are not clear and concise as is required by CPR 16.4 1(a). The Claimant’s legal representatives are known to be a serial issuer of generic claims similar to this one. HM Courts Service have identified over 1000 similar sparse claims. I believe the term for such behaviour is ‘roboclaims’ and as such is against the public interest.[/FONT][FONT=&quot]
Practice Direction 3A which references Civil Procedure Rule 3.4 illustrates this point:[/FONT]

[FONT=&quot]3) [/FONT][FONT=&quot]The Claimant has not complied with the pre-court protocol:[/FONT]
[FONT=&quot]a) [/FONT][FONT=&quot]When requested for concise details of the claim (in line with Para 6(a) Para 6(c)), such as a specific location, a contract with the land owner and how the claimed amount had been arrived at, the Claimant either ignored the request or stated it would only be provided in their witness statement if the matter went to court.[/FONT]
[FONT=&quot]b) [/FONT][FONT=&quot]When requested that we consider using ADR, as Para 8 suggests, by using the Claimant’s own Trade Association’s recommended ADR (Parking on Private Land Appeals) it was dismissed with no satisfactory answer. Due to the above the Defendant would refer the court to Para 11 & 14(c) on the unreasonableness of dismissing ADR.[/FONT]
[FONT=&quot]c) [/FONT][FONT=&quot]The Defendant would refer the court to Para 4 on non-compliance and sanction, and also point out that there can be no reasonable excuse for the Claimant's failure to follow the Pre-action Conduct process as this claim was issued by the Claimants legal representative so they clearly had legal advice before issuing proceedings.

[/FONT] [FONT=&quot]On the basis of the above, and for similar reasons cited by DJ Cross of St Albans County on 20/09/16 where a similar claim was struck out without hearing, due to Claimaint’s legal representatives’ [/FONT][FONT=&quot]particulars of claim being “incoherent”, failing to comply with CPR. 16.4, “providing no facts that could give rise to any apparent claim in law.” Also on 27/07/16 DJ Anson of Preston County Court ordered the Claimaint’s legal representatives’ file new particulars of claim due to them being deficient, which they failed to do and the claim was stuck out. Due to the above I request that the court strike out the claim for want of a cause of action. Please note that if the Claim is struck out I still wish to continue with the Counterclaim.[/FONT]
[FONT=&quot]Yours sincerely,
[FONT=&quot]JimmyChan[/FONT]
[/FONT]

Change Madame to 'Madam'

Haha thanks!

When it comes to the covering letter for Gladstones, can I just send the Directions Questionnaire with a covering letter which says "Please find enclosed my N180" or do I have to send them what I am sending to the court?