Thank you so much.

hi Andy, do you have time to tweak this? i have to file tomorrow i think

first draft, my only concern is I had a pre legal assessment letter so does that mean they have complied with Pre action protocol(2)? Particulars of claim for reference only 1. The claim is for the sum of £1771 arising from the defendants breach of a regulated consumer credit agreement reference under no XXX 2.The defendant has failed to remedy the breach in accordance with a Default Notice issued pursuant to ss. 87(1) and 88 of the CCA. 3.The claimant claims the sums due from the defendant following the legal assignment of the agreement from IDEM Capital securities Ltd (EX EGG PLC). Written notice of the assignment has been given. 4.The Claimant claims 1. The sum of £1771 2. Costs. Defence 1.The Defendant contends that the particulars of claim are vague and generic in nature. The Defendant accordingly sets out its case below and relies on CPR r 16.5 (3) in relation to any particular allegation to which a specific response has not been made. 2. Paragraph 1 is noted. Whilst I have had dealings with Egg PLC in the past I cannot recall the specifics of the alleged agreement. 3.Paragraph 2 is noted. Although as 2 I cant recall the agreement so I am not aware of service of a Default Notice pursuant to sec 87(1) CCA1974 by the original creditor . 4. Paragraph 3 is denied .I have no knowledge of who the claimant is nor have I been provided with any Notice of Assignment pursuant to the Law of Property Act 1925. 5.. On receipt of this claim I requested information pertaining to the claim from Howard Cohen & Co Solicitors by way of a CPR 31:14 request sent via 1st class recorded post on 21st May 2021. Further to the above I sent Hoist Finance UK Holdings 3 LTD a section 78 request via 1st class post on 2nd June 2021. To date, neither Howard Cohen nor Hoist Portfolio are yet to furnish me with the requested information . 6.Therefore the Claimant is put to strict proof to a) show how the Defendant has entered into an agreement; b) show and disclose how the Claimant has reached the amount claimed for; c) show and evidence the nature of breach and service of a Default Notice pursuant to Sec 87 (1) CCA1974. d) show how the Claimant has the legal right, either under statute or equity to issue a claim; 7. As per Civil Procedure Rule 16.5 (4) it is expected that the Claimant prove the allegation that the money is owed. 8. Until such time the claimant can comply with my section 78 request dated 2nd June the claimant is prevented from enforcing the alleged debt pursuant to section 78.6(a) By reasons of the facts and matters set out above, it is denied that the Claimant is entitled to the relief claimed or any relief.

So haven't heard from anyone, Bank said they can't help with old payments! i'll start my defence?

Thanks so much for your quick response. old bank, can't access it at all, tried to find paper bank statements but haven't got them CITI bank still awaiting a response from my email. i'll send the CCA request to hoist tuesday.

Received a response from my CPR request: we acknowledge receipt of your letter dated (doesn't put the date in) made under CPR for documentation mentioned in our PoC we are currently in the process of retrieving the documents requested Therefore, please accept this letter as our agreement to a general extension of time. once we have provided you with the documents requested we will grant a further 14 days for you to respond to the claim form as you feel appropriate do i still work on my defence?

Just called again, was given another number, which i called, went to answerphone, they are not taking calls due to COVID lol and to email, so emailing them now

Thanks, i've just logged into a v old email account and found something from Egg from 2005 for a loan, so i'm presuming its this...there is no acc no though so i can't match it up. i'll try CITI again.

went round in a circle with them, rang their main number, they transferred me to Egg/Barclaycard who then transferred me to another number where nobody answered. tried 3 times and again today

no, sent letter to the solicitor, tried to contact Egg but they said they couldn't help!....

no, i changed bank accounts in 2019

thank you again. i've done the CPR and will get it posted...will start reading about defence etc

pre legal assessment came from RW, uses same 10 digit account no and states due to: HFUKH3L (Ex IDEM EX EGG) then the response to that came 6 mths later using the same account no from Hoist finance , i'll try and scan and upload both letters thank you so very much for your help with this these are the letters. letters PDF.pdf i have checked my credit file again, there is nothing on there for this amount and anything around that time is paid and closed

i really have no idea what it is, did Egg do loans? i remember having a Egg CC but this is so old i have no idea what it is

10

got to be over 10 years ago....there is a reference no

Name of the Claimant ? Hoist Finance UK Holdings Date of issue – 18th may 2021 Particulars of Claim What is the claim for – 1. The claim is for the sum of £1771 arising from the defendants breach of a regulated consumer credit agreement reference under no XXX 2.The defendant has failed to remedy the breach in accordance with a Default Notice issued pursuant to ss. 87(1) and 88 of the CCA. 3.The claimant claims the sums due from the defendant following the legal assignment of the agreement from IDEM Capital securities Ltd (EX EGG PLC). Written notice of the assignment has been given. 4.The Claimant claims 1. The sum of £1771 2. Costs. What is the total value of the claim? 1956 Have you received prior notice of a claim being issued pursuant to paragraph 3 of the PAPDC (Pre Action Protocol) ? no, only pre legal assessment Have you changed your address since the time at which the debt referred to in the claim was allegedly incurred? Yes Did you inform the claimant of your change of address? No Is the claim for - a Bank Account (Overdraft) or credit card or loan or catalogue or mobile phone account? CC??? When did you enter into the original agreement before or after April 2007 ? not sure possibly pre Do you recall how you entered into the agreement...On line /In branch/By post ? not sure Is the debt showing on your credit reference files (Experian/Equifax /Etc...) ? No Has the claim been issued by the original creditor or was the account assigned and it is the Debt purchaser who has issued the claim. Debt purcahser Were you aware the account had been assigned – did you receive a Notice of Assignment? no idea Did you receive a Default Notice from the original creditor? Do not remember as so long ago Have you been receiving statutory notices headed “Notice of Sums in Arrears” or " Notice of Arrears "– at least once a year ? not sure Why did you cease payments? At least 5 years ago, What was the date of your last payment? No idea Was there a dispute with the original creditor that remains unresolved? Don’t know Did you communicate any financial problems to the original creditor and make any attempt to enter into a debt management plan? Don’t no i had a pre legal assessment, and in that i clearly stated that i had no knowledge of the debt or accepted this debt, this is when i requested the contract ..should of said the pre legal assessment was from Robinson Way not from this Hoist Finance

i apologise if this is the wrong area of the forum, i'm a bit lost. received a letter in Nov 2020 from Robinson Way - pre legal assessment for a debt i have no knowledge of and appears to have been sold 3 times responded to letter stating i have no knowledge of this debt or accept any liability for any such debt, requested a copy of the agreement response received from Hoist finance (different company??) in april 2021 stating that they are unable to source the additional information i requested. Today received a Claim Form, i have filed a AOS but am now stumped as particular of claim relate to failed to remedy the breach in accordance with a default notice issued pursuant to SS 87(1) & 88. any help would be extremely grateful as i have checked my credit file and can find nothing relating to this