Great! Many thanks Andy, for all the supports...... I hope everything go well.......

Can you please check i have re frame it ....

ok, will amend it now.... thanks

Hi Andy, please help to check if ok... thanks IN THE county court of XXXXXXX CLAIM NO: BETWEEN: LOWELL PORTFOLIO I LTD Claimant -and- Defendant WITNESS STATEMENT OF xxxxxxxx I. xxxxxxx the defendant in this claim appear before the court as a litigant in person make the following statement believing it to be true will state as follows:- 2.It is admitted that I have in the past had financial dealings with HBOS . 3. To the best of my knowledge I cannot recall the alleged debt in question and I have not received any documentation since xxxxx 2011 regarding this loan in any form until xx xxxx 2014 when I received a County Court claim form from claimant solicitor (BC). Prior to this I had received no correspondence from the Claimant. As a result of this claim I submitted my defence via MCOL. (xxxx refers) 4.Therefore to enable to verify this claim, on the xxxxx I sent a request to claimant solicitor under CPR 31.14. This was sent by recorded delivery and was delivered to xxxxx on 7th May 2014. I refer to a copy of this letter and proof of delivery attached. I requested for information pursuant to CPR 31.14. Namely to show how I entered into an agreement Show how the claimant quantified the amount claimed And to show how the claimant has legal right either under statute or equity to issue a claim in their name. Given that at this stage the claim is trackless and not allocated, CPR 31.14 does apply and the claimant is required to comply to validate and assist in verifying its claim. Although it is a civil request the court expects parties to communicate to try to narrow any differences. Given that the claimant readily issued a claim based on documentation referred to within their particulars one would assume that they would be more than happy to comply to prove that any claim is valid and therefore eradicating any need to defend or proceed to trial. I understand that this avoidance can be sanctioned when the question of costs arise as deemed as being unreasonable. As per CPR 16.5(4) it is expected that the claimant prove the allegation that any money is owed and disclose all documentation relied upon as the basis of their claim at trial also ensure that the original are available. 5. On the xxxxMay 2014 I sent a request to xxxx pursuant to S.77/78 of the consumer credit Act 1974 requesting statutory information in relationship to the account in question. This was sent by recorded delivery and was delivered and signed for on the xxxx May 2013. (xxxx refers) 6. The correspondence from the claimant in response to my requests under CPR 31.14 (dated 2nd May 2013) and s.77/78 Consumer Credit Act 1974, the claimant have stated that they are under no obligation to disclose any documentation on which their claim is based on. 7. It is denied that I was informed of assignment of this debt neither by the original creditor nor the assignee. For an assignment to be legally binding it must be pursuant to the Law of Property Act 1925 (sec136) Assuming it’s a Legal Assignment Only the benefit of an agreement may be assigned. The assignment must be absolute. The rights to be assigned must be wholly ascertainable and must not relate to part only of a debt. The assignment must be in writing and signed under hand by the assignor. Notice of the assignment must be received by the other party or parties for the assignment to take effect. Again it is denied any Notice of Assignment was ever received. 8. It is in my opinion that the claimants claim is fanciful contains no proof, and uncorroborated. Totally unaware of the details of debt they have purchased and expecting judgment/relief be granted, relying on the court to base its decision on assumption and basis of probabilities. It is therefore submitted that the claimants be ordered by the court to quantify, verify, substantiate and disclose all evidence relied upon and should the claimant fail to that, their claim be struck out under CPR 3.4 as having no basis. I believe that the facts stated in this Witness Statement are true. Signed ………………. November 2015

Thanks

Please Andy, is that all i have to do....

Thanks Andy, I have removed it......

I will remove the facility also remove i deny entering an agreement....

I have removed the current account element, please check if anymore.....

I should remove the current account from the above ... .... what current account are you referring to please?

okay, i have checked the tread I can see any personal loan witness statement..... any link please...

No, it's for Loan please

Here is what I have been able to come up with, I am sure it is not too late and i can still drop it off tomorrow.....Please help to amend...Thanks IN THE county court of XXXXXXX CLAIM NO: BETWEEN: LOWELL PORTFOLIO I LTD Claimant -and- Defendant WITNESS STATEMENT OF xxxxxxxx I. xxxxxxx the defendant in this claim make the following statement believing it to be true will state as follows:- 1.It is admitted that I have in the past had financial dealings with HBOS. 2. It is admitted that I accepted a service offered by xxxxx to carry out general banking. 3. It is denied that I was informed of assignment of this debt neither by the original creditor nor the assignee. For an assignment to be legally binding it must be pursuant to the Law of Property Act 1925 (sec136) Assuming it’s a Legal Assignment Only the benefit of an agreement may be assigned. The assignment must be absolute. The rights to be assigned must be wholly ascertainable and must not relate to part only of a debt. The assignment must be in writing and signed under hand by the assignor. Notice of the assignment must be received by the other party or parties for the assignment to take effect. Again it is denied any Notice of Assignment was ever received. 4. It is admitted on receipt of the claim form I did request for information pursuant to CPR 31.14. Namely to show how I entered into an agreement Show how the claimant quantified the amount claimed And to show how the claimant has legal right either under statute or equity to issue a claim in their name Given that at this stage the claim is trackless and not allocated, CPR 31.14 does apply and the claimant is required to comply to validate and assist in verifying its claim. Although it is a civil request the court expects parties to communicate to try to narrow any differences. Given that the claimant readily issued a claim based on documentation referred to within their particulars one would assume that they would be more than happy to comply to prove that any claim is valid and therefore eradicating any need to defend or proceed to trial. I understand that this avoidance can be sanctioned when the question of costs arise as deemed as being unreasonable. As per CPR 16.5(4) it is expected that the claimant prove the allegation that any money is owed and disclose all documentation relied upon as the basis of their claim at trial also ensure that the original are available. 5. It is in my opinion that the claimants claim is fanciful contains no proof, and uncorroborated. Totally unaware of the details of debt they have purchased and expecting judgment/relief be granted, relying on the court to base its decision on assumption and basis of probabilities. It is therefore submitted that the claimants be ordered by the court to quantify, verify, substantiate and disclose all evidence relied upon and should the claimant fail to that, their claim be struck out under CPR 3.4 as having no basis. I believe that the facts stated in this Witness Statement are true. Signed ………………. November 2015

I don't want to mess up all the efforts.......

i am sorry ... lesson learn ......