Hi. noted and thank you. How do I word the letter needed that you advised to accept signing there consent form? Do I simply state I have reconsidered and will agree to sign the consent upon agreement she pays her own costs???? That’s all I write? Do I mention further action? Does the consent form he provided stop me making a fresh, methodical, concise claim and when can I make the new claim? Please advise. I feel stressed that I should be addressing this asap.

A Notice if Discontinuance. they claim invalid service ( she spelt a wrong letter when forwarding her reps details). they claim this was due to dyslexia. they are also claiming some of my allegations have no evidence. one advisor said it’s rarely overturned so wait to hear but they are putting her fists on me for not signing discontinuance consent. BF says agree to discontinue , make particulars concise but I do not know how, an approach methodically ????? How, what does that mean. I thought I had !!!! thank you. LA

please do not give up on me sir. i am trying desperately hard. As a society, she cannot get away with this. I am trying to hold a puppy mill to account. It is not just about compensation. She has been doing this for years without being held to account. I would obviously prefer not to delay further by agreeing to set aside and I have to consider, even if I did, how I would make this more concise. Which of these are uncoverable damages please, I could agree and amend if I no how but asking for a refund, the cost of replacement item and vet fees in the initial days following purchase appear the least i can ask for. You advised I could not claim for the surgery he needed because I had not paid for it yet so I crossed off all of the surgeries he needed and only claimed for the above 3 things. If it were you, how would you make it more concise. what would you delete/add. Chances of a successful overturning of the order? How am I responsible for her costs when she obstructed service ( I have months of texts off her - not one with a spelling issue and never a request for verbal communication), and insisted on the court action in writing. I have the envelope marked by Royal Mail with her refusal to accept service. Constant obstruction to justice. Should I agree to set aside, offer out of court opportunity to settle then go again ? but again, how do I make this more concise. Do I reduce the breaches? reduce the text content within the allegations? If I have to list her breaches by literally going through her license obligations, how do I reduce it if thats how many breaches were there. Should I reduce the ones I cannot prove such as NO license being displayed. It was not, its a license breach but i do not have paper work for it to prove it. I note the denials come on points I cannot prove although I had a witness who can verify. Then leave the allegations I have receipts/reports for? Bump up the Consumer Breaches ? Could I make it more concise by simply putting the things she has admitted to in the particulars only deviating from that where I have evidence of things in the denials? I appreciate its been a long thread but few hold puppy farmers to account so these cases rarely even get to court. I cannot control how long it goes on for or how many interactions/documents/orders or letters will crop up throughout. However, this is real and it helps others who will hold puppy farms to account - it also highlights the issues that are faced when you are going it alone. Please continue to support me through this process.

Sir I made the PoC concise and you commented on obtaining reports from vets etc which I did. No comment was forwarded when I uploaded the last version of the particulars so I thought they were good to go. I tried very hard to do all you asked me to do - I have no idea what I am doing so i would not intentionally go my own way. Even if I agreed to set aside - I am not sure how I could make it more concise. You advised go through her licensing agreement and identify the breaches with the particulars. What are the chances of it being overturned anyway, will the courts give me the chance to address there comments before ruling. If i agree to overturn then re approach more methodically, how would I make it more concise when those are the issues within the license that were breached. I asked for a refund, replacement of goods cost and the immediate vet fees i spent. These are not unrecoverable damages. Would more concise be sticking to the mis representation and the purchasing laws rather than including the license breaches? Even if their application led to a hearing, the judge would still award the basics like a refund, replacement and vet fees. There is apparently a law that simply states dogs with heart issues should never be sold but thats via word of mouth and I have not idea how to find it.

No because I do not have it - as previously explained. This was never received from the courts. mad advised I am chasing it but they are taking 3 weeks to address emails and respond.

Hi, I have a very stressful update. I have received the following files from the breeders solicitors - its all very stressful and scary. I have allowed until Jan 1 for consideration of the claim and payment by not enforcing HCEO but I have refused to sign any consent orders on the basis I have no right to overturn a court order nor am I legal to know what I am signing. There is another file to follow but the site would not upload it with these too. file 4 to follow. I would greatly appreciate some help and advice please. LA 1 Witness Statement of Jonathan Stimmler 15_12_23(22389506.9).pdf 2 K02BM044 - Arnold v Turne2 Exhibit JRS1 to Witness statement of Jonathan Stimmler - 15_12_23(22390714.2).pdf 3 K02BM044 Arnold v Turner - Witness Statement of Jonathan Stimmler 15_12_23(22389506.9).pdf File 4 4 K02BM044 - Arnold v Turner - Application Notice - 15_12_23(22389645.1).pdf

Ok I will call them. so can I get help with those two sections on N293a please

The only thing i received was the Issue form where I ticked and returned etc. Then notification the judgement was made. Is all this relevant for me to just want to know how to complete the N293a?

Ok well i never received the N1 back with a seal. should I call the courts?

I am hoping you mean the document now uploaded as this is the only other thing i have had from the court. Re Service: I asked her where she wanted service. She provided a solicitors name that i could not find on google. I challenged the information that she gave so she then forwarded a text with the full name & address of the solicitors used. I provided her with a recorded delivery notification of a claim, sending a copy to her solicitors as she had detailed and her LA. Within that, she was advised that the formal claim would be sent shortly by the same means to the same recipients - from that point she refused recorded deliveries she therefore refused to accept the detailed claim herself. She was obstructive to ensuring justice was served from day one and false rep details were given. I sought advice throughout and was never told to ensure her solicitors were open/confirming service. She had not even contacted them to instruct for service - she had not intention because she knew she would need to start paying. She thought i was going away and failed to contact her own reps until she received the court confirmation that the debt was due. notice of issue.pdf

Bless you thank you. are these any good? breeder solicitor email 2.pdf judgement cag.pdf Letter to XXX 30 November 2023 enc.(22331119.1).pdf

Well the solicitors letter was sent pdf, It will not allow any form of editing and I’m trying to hide my details so it needs editing. I presumed the content was what mattered so I copied and issued the content. I will screen doodoo the order and upload. I received a link fir a donation so I responded.

Hi, Yes i will donate as I have been helped massively. So as requested, my full particulars, their response once they realised the order was going through, i refused as you advised previously then received their second response entitled accordingly but found with the same pdf doc for breeder solicitor contact. i do not want to make any errors on the N293a form guidance does not make sense and stops at part 2. N1 JAX cag version.pdf Jax PoC Cag final.pdf breeder solicitor contact cag.pdf

Hi. Sorry, I missed your message asking for the docs. yes, you have previously checked the claim form which was uploaded to this site but yes I will reload it later today. I have no defence to upload but two letters off her solicitor. I’ll get them into PDF then upload them both later.

Thank you so much. I have cognitive issues that impact these forms being understood. still a little stuck. In section 1, in the same box where to you tick writ of control, there’s a brief paragraph starting “I intend to enforce the judgement or order by execution ……..and require this certificate for this purpose”. Theres a dotted line immediately below, do I enter any thing there? Or blank? Part 3, top right corner - “Seal a writ of (control) (possession) directed to the: To…………….., to an enforcement officer bla bla” or ‘The enforcement officers authorised to enforce writs of execution bla bla to the district of- ————-“ which one and what do I enter please. In part 3, section C, do I write ‘cash’ or the total amount? Now, section C address for service - is that the breeders address or the address I gave for service which is their argument for invalid initial service or the ‘correct address’ she claims it should have gone to. Yes Is that telling me to use breeders address or her solicitor correct address? Thank you for your help.

Hi. I am trying to initiate the HCEO. Can anyone help with the form please I am stuck on the N293a form. In the right sided box in section 1- I have no separate ref numbers for claimant or defendant - leave blank or N/A or re enter claim number? part 1: there’s a box on the far right below the claim number section. Do I enter anything into the ‘ I intend to enforce the judgement or order by execution …. … In the High Court and require this certificate for this purpose’. What purpose? Settlement of order ok? section 3 - is that for me to complete? County Court Claim Number - is that ‘The Claim’ number. I do not have a high court enforcement number? Does that follow? Do I leave it blank ? top right hand corner, 2nd line: To “?????’ Or ‘??????’ against ??? The breeder? section A - does bailiff add costs there or my costs ( Iv paid £75 for the HCEO - Just enter that?). section B - I’d that the interest only amount awarded by the court? Section C - Possession of …. What- the total amount entered there? Plus my £75? Now, section C address for service - is that the breeders address or the address I gave for service which is their argument for invalid initial service or the ‘correct address’ she claims it should have gone to. it’s always the forms that get me.

Hi. Well I have not anything from the courts about it being overturned. I have refused to sign their request to wait for 28 days so I am going to iniate thd HCEO. uf they thought they could stop it or reverse it or delay it - they would have done so. They would not be asking me for more time !!! As advised I have waited to begin the HCEO and informed them she has until tomorrow - 7 days post deadline.

Many thanks for that template. As mentioned above, I had already replied saying much the same thing so your response confirms my own - thank you. Following last weeks advice that these orders are rarely overturned, I just stuck to my guns. It was clear they did not know the facts though so i did add detailed examples of where she proved she certainly did not show signs of dyslexia in detailed, well punctuated texts but neither did she ask for verbal communication because of it. In the legal world this may be classed as narrative but i thought the more accurate evidence i can give them that she is not telling the whole truth means they advise her sooner to pay and not encourage this kind of nonsense because they do not really know the facts - but point taken and lesson learned. i did not think to ask for evidence of the dyslexia or how that impacts her understanding - she is in partnership with her husband who made all the decisions on the purchase day so is fully aware of this action - their LAO has been visiting since i reported her too. given my response was a little detailed, i have not uploaded it on this occasion. I may as well start the HCEO action as they clearly would have applied to court last week if they thought they could win - do you think?

so..... if they thought they could overturn, they would have - right? She hates spending money so she obvs left solicitor involvement for advise throughout until the day she got the order so knew she had no choice. He must have warned her she has little chance and that further costs will apply of she loses?? I am wandering if I have sat tight for long enough as they would have made that emergency order to overturn last week surely/ I cannot imagine they would write to me with requests for delays if they thought they could get it overturned. Is clear from the things her rep has said that she is not telling him the truth. As i provide more info, their stance changes based on the info i provide them. I have suggested he pushes for a truthful heart to heart with his client as he is not getting so at the Mo. She was not dyslexic when she saw the notification of the claim received by signed for delivery then refuse all other recorded delivery mail as the notification informed her to expect it - my mistake but you live and learn and it has actually worked in my favour

Hi, I have an update. The breeders solicitor contacted me again today attaching a consent order for me to stay it for 28 days. You may remember they claimed no service but clarified how many times i checked the info she gave me with her and i then alleged she had given spurious details deliberately to avoid service. They approach today stating she was not intending to provide incorrect details - she is dyslexic. I pointed out that she was not dyslexic when she opted to text rather than call. Nor when she wrote she wanted court resolution, that dyslexics are able to copy from screens and given the gravity of the situation she would have asked for spousal support if dyslexic and writing important texts. I also highlighted she had received docs by me by recorded delivery as they claim she has had no time to consider the options given no claim form was received. i have reminded them of the 8 month convos by text, recorded delivery evidence of the notification of the claim and her following refusal to accept recorded deliveries for service. i have refused their requests stating HCEO will commence this friday and if they thought they could overturn it, we would not be discussing this now. Regards Lesley

Ok. Will the court give me the chance to prove she sent fake details to prevent service? should I contest it immediately so they do not even overturn it or wait for court contact? what is the point of making orders of someone can suddenly realise they are in trouble after an order with no engagement prior and have it stopped? should I contest niw or wait ? regards lesley

Thank you. I will commence this action tomorrow as I cannot do so until after the 1/12/23. thank you. lesley.

Agreed. I was going with the writt of control bug her date for payment was today so I cannot initiate it until tomorrow. N293a is the form they told me to use- is that what you refer to with HCEO? It’s above £5k so the courts have advised it’s a higher level of collection techniques used by bailiffs. Her husband has gun crime offences and is out there in google so true - should I advise the bailiffs he uses guns or is that not my place - I worry for them.

Thank you for that, I have simply told them if they succeed in their request for it be set aside, I will be asking for a CCJ at the hearing for a charge on her property. She supplied her reps name. It didn’t appear on google so I text her to say they didn’t exist. she text back confirming their name and address for service. I sent copies to her home by recorded delivery. She refused it and it was returned marked as refused to accept by the a Royal Mail. She has provided fake details and was asked twice for confirmation. So I believe she did this deliberately. If they are claiming they never knew of the action, won’t the court re consider the judgement? Regards lesley.

Hi, Update: the breeder has now had a solicitors letter sent to me refusing to accept judgement based on a faulty service ( claiming the name was spelt wrong etc), no PoC has been received , I must stop the judgement or pay her costs in court as she now seeks an urgent order based on incorrect service. I explained she confirmed their details twice upon being asked where she wanted docs to go and that she refused delivery at her home address of the action coming she’s obstructed service herself. lesley