Bryan Carter Says No **WON THEY GAVE UP**

[The GodMother]

Hi Paul.

 

I was just going to see if Awake now had pmd you.

 

Thanks for the advise about the splitting of the claim. I will look out for this when someone eventually contacts me regarding shop direct.

[OLIVE.FAMILY]

I have just read through this thread and I would like to say well done Awakenow. I think I can say I know exactly what you are going through. I too fell behind on countless debts because of my childrens diaabilities sddenly taking a turn for the worst and then my husband decided to get ill aswell. I too hid my letters unopened where ever i could find a space(mainly under the bed). I had council tax demands, electric wanting to fit metres as well as all the people knocking on the door.

 

I just wanted to say now you are taking action thinks will get better. One step at a time deal with Bryan Carter and then everybody else. I actually had a letter fom Bryan Carter as well the other day. I am claiming all my charges back from Littlewoods which will clear this debt and give me extra. You are now in control of these people and you tell them what you expect of them. They are nobodies (sorry they make me sooooooo angry)

 

Good luck with all that you are doing. I can truly appreciate how hard it is to remain focused especially with a disabled child. With the help and support from all on this sight though you will come out on top and focused once again. Truly Awake for good

 

TAKE CARE

OLIVES

[AwakeNow]

hi awake hope you are ok i have pm a mod to look at this thread to guide you through what you need to be doing

patrickq1

Thank you very much patrickq1.

 

Sorry not ot have responded sooner, been off line due to sorting electric and my youngest child's birthday. Thank you for your continued interest and help.

[AwakeNow]

Hi there

 

Ok, had a read of the thread, im not surprised one bit by carters and this practice of refusing access, maybe if they learnt to sufficiently particularise their claims and supply supporting documents required for this type of claim. then people wouldn't be asking for more info

 

firstly, don't worry about their not providing the documents, by doing this, they are taking a huge spike and impaling themselves upon it, Also, if not happy with doing this, they are acting unlawfully in splitting a single cause of action into 2 or more claims.this is directly against the County Courts Act 1984 Section35 .i will post up a defence to this claim in the morning that i have on my pc

 

regards

paul

Oh thank you very very much Paul. I'm not exactly sure what you mean by their splitting claims - I think my brain has come a lilttle bit to overload at the moment.

 

I have got another letter from Bryan Carter regarding another debt with the same company - is this what you refer to? Forgive my ignorance its been a long time since I have tried to assimilate so much information into a short period of time.

 

However any advice and suggestions I would be very grateful as I am now sorting out the electric bill debt and find I haven't got any bills from that for the past 2 years so its like a muddle at the moment trying to sort out who I owe money to and for what and how much - sorry to be a burden.

: - (

[AwakeNow]

I have just read through this thread and I would like to say well done Awakenow. I think I can say I know exactly what you are going through. I too fell behind on countless debts because of my childrens diaabilities sddenly taking a turn for the worst and then my husband decided to get ill aswell. I too hid my letters unopened where ever i could find a space(mainly under the bed). I had council tax demands, electric wanting to fit metres as well as all the people knocking on the door.

 

I just wanted to say now you are taking action thinks will get better. One step at a time deal with Bryan Carter and then everybody else. I actually had a letter fom Bryan Carter as well the other day. I am claiming all my charges back from Littlewoods which will clear this debt and give me extra. You are now in control of these people and you tell them what you expect of them. They are nobodies (sorry they make me sooooooo angry)

 

Good luck with all that you are doing. I can truly appreciate how hard it is to remain focused especially with a disabled child. With the help and support from all on this sight though you will come out on top and focused once again. Truly Awake for good

 

TAKE CARE

OLIVES

Heartfelt Thanks Olives,

 

I am truly amazed at how much good-will I have found on this site, it has been an eye opener for me as I am used to dealing with a completely different type of person during my life and would never believe before now, although always trusting there would be, such warmth and generosity of spirit existed.

 

Thank you so much for your warm support and understanding,

 

Hugs to you and yours,

 

Maria x

 

I hope your family remain strong

[pt2537]

Hi there

 

sorry for not looking back in earlier,

 

no, what i mean is this,

 

 

say for example you have a debt of £1500 and say its a catalogue for example, now you miss 3 or 4 payments and go into arrears of say £500 now they should issue a default notice and follow procedure etc, at the point where they instigate legal action they should be bringing the claim for the full amount owing of £1500 NOT £500 as this is splitting one action ie £1500 into two actions and that is prohibited under section 35 of the county courts act

[The GodMother]

Hi awake now.

 

What paul means by spliting there claims is this

 

They send you a bill for say £100.

They issue a court claim for say £50.00 plus costs.

They put on the claim we reserve the right to reclaim threw the courts any balance that is left owing. As in the £100.00

 

This is what splitting there claim means as they are just going for there costs.

 

same as paul said basically

[pt2537]

In the xxxxxxxx County Court

Claim number

 

 

 

 

 

Between

 

xxxxxxxxxxx- Claimant

 

and

 

 

- Defendant

 

 

 

Defence

 

1. I xxxxxxxxx of xxxxxxxxxxxxx am the defendant in this action and make the following statement as my defence to the claim made by xxxxxxxxxxxxx

 

2. Except where otherwise mentioned in this defence, I neither admit nor deny any allegation made in the claimants Particulars of Claim and put the claimant to strict proof thereof.

 

3. The Defendant is embarrassed in pleading to the Particulars of Claim as it stands at present, inter alia: -

 

4. The claimants' particulars of claims disclose no legal cause of action and they are embarrassing to the defendant as the claimant's statement of case is insufficiently particularised and does not comply or even attempt to comply with CPR part 16. In this regard I wish to draw the courts attention to the following matters;

 

 

a) The Particulars of Claim are vague and insufficient and do not disclose an adequate statement of facts relating to or proceeding the alleged cause of action. No particulars are offered in relation to the nature of the written agreement referred to, the method the claimant calculated any outstanding sums due, or any default notices issued or any Notice of Assignment required for the claimant to have a legitimate right of action for the purported debt or any other matters necessary to substantiate the claimant's claim.

 

b) A copy of the purported written agreement that the claimant cites in the Particulars of Claim, and which appears to form the basis upon which these proceedings have been brought, has not been served attached to the claim form.

 

c) A copy of any evidence of both the scope and nature of any default, and proof of any amount outstanding on the alleged accounts, has not been served attached to the claim form.

 

.

5. Consequently, I deny all allegations on the particulars of claim and do not know what case I have to meet

 

Abuse of the process

6. It is also noted that the claimant is trying to conduct this claim contrary to s35 of County Courts Act 1984 as I note the claimant has split once cause of action into two separate claims. This is unlawful as laid out in section 35 CCA 1984 and it is requested that the court strike out this case as a clear abuse of the process

 

Credit account

 

7. The account no xxxxxxxxxxxx referred to relates originally to a Littlewoods catalogue account and furthermore is classed as running-account credit as defined within section 10 (1) (a) Consumer Credit act 1974 which states inter alia

 

(a) running-account credit is a facility under a personal credit agreement whereby the debtor is enabled to receive from time to time (whether in his own person, or by another person) from the creditor or a third party cash, goods and services (or any of them) to an amount or value such that, taking into account payments made by or to the credit of the debtor, the credit limit (if any) is not at any time exceeded; and

 

8. Therefore, based upon the claimant's particulars of claim, the claimant would appear to be trying to circumvent the regulation of the Consumer Credit Act 1974 under which this account type is governed.

 

9. The Consumer Credit Act 1974 requires that where credit is provided by a creditor to a debtor, there must be an agreement between parties containing the prescribed terms as set out in section 60(1) of the consumer credit act 1974 and signed in the prescribed manner as laid out in section 61(1) (a) Consumer credit act 1974

 

10. Therefore for the claimant to have a legitimate right of action they must hold a credit agreement compliant to the Consumer Credit Act 1974 and the regulations made under the Act and must be able to produce this before the court

 

11. The Claimant is therefore put to strict proof that such agreement exists

 

The Request for Disclosure under the CPR

 

12. Further to the case, on xx/xx/2007 I requested the disclosure of information pursuant to the Civil Procedure Rules, which is vital to this case from the claimant. The information requested amounted to copies of the Credit Agreement between and any default or termination notices, a transcript of all transactions, including charges, fees, interest, alleged repayments by myself and payments made by the original creditor. Also any other documents the Claimant seeks to rely on, including any default notices or termination notice, and a copy of the Notice of Assignment required to give the claimant a legitimate right of action.

 

13. This request was sent by royal mail special delivery document number XXXXXXXXXX and was received by the claimant on xx/xx/2007

 

 

14. To Date the claimant has ignored my request under the CPR and I have not received any such documentation requested. As a result it has proven difficult to compose this defence without disclosure of the information requested, especially given that I am Litigant in Person

 

Consequences of Non Disclosure of the agreement

 

15. The courts attention is drawn to the fact that the without disclosure of the requested documentation pursuant to the Civil Procedure Rules I have not yet had the opportunity to asses if the documentation the claimant would need to be relying upon to bring this action even contains the prescribed terms required in Consumer Credit (Agreements) Regulations 1983 (SI 1983/1553) which was amended by Consumer Credit (Agreements) (Amendment) Regulations 2004 (SI2004/1482). The prescribed terms referred to are contained in schedule 6 column 2 of the Consumer Credit (Agreements) Regulations 1983 (SI 1983/1553)

 

16. The prescribed terms referred to are contained in schedule 6 column 2 of the Consumer Credit (Agreements) Regulations 1983 (SI 1983/1553) and are inter alia: - A term stating the credit limit or the manner in which it will be determined or that there is no credit limit, A term stating the rate of any interest on the credit to be provided under the agreement and A term stating how the debtor is to discharge his obligations under the agreement to make the repayments, which may be expressed by reference to a combination of any of the following--

1. Number of repayments;

2. Amount of repayments;

3. Frequency and timing of repayments;

4. Dates of repayments;

5. The manner in which any of the above may be determined; or in any other way, and any power of the creditor to vary what is payable

 

 

 

 

17. Further more the courts attention is also drawn to the authority of the House of Lords in Wilson-v- FCT [2003] All ER (D) 187 (Jul) which confirms that where a document does not contain the required terms under the consumer credit act 1974 and the Consumer Credit (Agreements) Regulations 1983 (SI 1983/1553) and Consumer Credit (Agreements) (Amendment) Regulations 2004 (SI2004/1482) the agreement cannot be enforced

 

18. With regards to the Authority cited in point 17, I refer to LORD NICHOLLS OF BIRKENHEAD in the House of Lords Wilson v First County Trust Ltd - [2003] All ER (D) 187 (Jul)

28.........I should outline the salient provisions of the Consumer Credit Act 1974. Subject to exemptions, a regulated agreement is an agreement between an individual debtor and another person by which the latter provides the former with a cash loan or other financial accommodation not exceeding a specified amount. Currently the amount is £25,000. Section 61(1) sets out conditions which must be satisfied if a regulated agreement is to be treated as properly executed. One of these conditions, in paragraph (a), is that the agreement must be in a prescribed form containing all the prescribed terms. The prescribed terms are the amount of the credit or the credit limit, rate of interest (in some cases), how the borrower is to discharge his obligations, and any power the creditor may have to vary what is payable: Consumer Credit (Agreements) Regulations 1983, Schedule 6. The consequence of improper execution is that the agreement is not enforceable against the debtor save by an order of the court: section 65(1). Section 127(1) provides what is to happen on an application for an enforcement order under section 65. The court 'shall dismiss' the application if, but only if, the court considers it just to do so having regard to the prejudice caused to any person by the contravention in question and the degree of culpability for it. The court may reduce the amount payable by the debtor so as to compensate him for prejudice suffered as a result of the contravention, or impose conditions, or suspend the operation of any term of the order or make consequential changes in the agreement or security.

 

29. The court's powers under section 127(1) are subject to significant qualification in two types of cases. The first type is where section 61(1)(a), regarding signing of agreements, is not complied with. In such cases the court 'shall not make' an enforcement order unless a document, whether or not in the prescribed form, containing all the prescribed terms, was signed by the debtor: section 127(3). Thus, signature of a document containing all the prescribed terms is an essential prerequisite to the court's power to make an enforcement order. The second type of case concerns failure to comply with the duty to supply a copy of an executed or unexecuted agreement pursuant to sections 62 and 63, or failure to comply with the duty to give notice of cancellation rights in accordance with section 64(1). Here again, subject to one exception regarding sections 62 and 63, section 127(4) precludes the court from making an enforcement order.

 

30. These restrictions on enforcement of a regulated agreement cannot be sidestepped.....

 

 

And further more

 

36. In the present case the essence of the complaint is that section 127(3) of the Consumer Credit Act has the effect that a Regulated agreement is not enforceable unless a document containing all the prescribed terms is signed by the debtor

 

49. ".............The message to be gleaned from sections 65, 106, 113 and 127 of the Consumer Credit Act is that where a court dismisses an application for an enforcement order under section 65 the lender is intended by Parliament to be left without recourse against the borrower in respect of the loan. That being the consequence intended by Parliament, the lender cannot assert at common law that the borrower has been unjustly enriched.

 

 

50. This interpretation of the Consumer Credit Act accords with the approach adopted by the House in Orakpo v Manson Investments Ltd [1978] AC 95, regarding section 6 of the Moneylenders Act 1927 and, more recently, in Dimond v Lovell [2002] 1 AC 384, another case where section 127(3) precluded the making of an enforcement order. In Dimond's case the restitutionary remedy sought was payment of the hire charge for a replacement car used by Mrs Dimond. The House rejected a claim advanced on the basis of unjust enrichment. Lord Hoffmann observed that Parliament contemplated that a debtor might be enriched consequential upon non-enforcement of an agreement pursuant to the statutory provisions. It was not open to the court to say this consequence is unjust and should be reversed by a remedy at common law: [2002] 1 AC 384, 397-398

19. The House of Lords and the Court of Appeal before it in considering the Wilson case held that if the agreement does not contain the prescribed terms outlined in Schedule 6 column 2 of Statutory Instrument 1983/1553 then the court couldn't issue an enforcement order. The House of Lords clearly considered it the will of parliament that where a lender did not comply with the provisions of the Consumer Credit Act 1974 and the Subsequent regulations then the lender does not have any recourse, they cannot side step regulation by any other means and weather it is considered right or wrong for the debtor not to have to repay an unenforceable debt becomes irrelevant where the requirements of the CCA 1974 and regulations are not met

 

 

20. I also refer to the website of Francis Bennion, the drafts person of the Consumer Credit Act 1974 and note in particular a PDF document that the honourable Mr Bennion has posted (located here http://www.francisbennion.com/pdfs/fb/2003/2003-061-consumer-credit-1974-s127-3.pdf ) which states

"As the draftsman of the Consumer Credit Act 1974 I would like to thank Dr Richard Lawson for his interesting and well-argued article (30 August 2003) on Wilson v First County Trust Ltd [2003] UKHL 40, [2003] 4 All ER 97. Dr Lawson may be interested to know that I included the provision in question (section 127(3)) entirely on my own initiative. It seemed right to me that if the creditor company couldn't be bothered to ensure that all the prescribed particulars were accurately included in the credit agreement it deserved to find it unenforceable, and that the court should not have power to relieve it from this penalty. Nobody queried this, and it went through Parliament without debate. I'm glad the House of Lords has now vindicated my reasoning and confirmed that nobody's human rights were infringed.

 

167 Justice of the Peace (2003) 773.

The default notice

 

21. Furthermore, since the account referred to in the particulars of claim is regulated by the Consumer Credit Act 1974, for a right to pursue action to exist; there are procedures, which must be followed under the Consumer Credit Act 1974. A default notice must be issued under s87 (1) conforming to the Consumer Credit (Enforcement, Default and Termination Notices) Regulations 1983 (SI 1983/1561) which sets out the form and content which default notices must include, without such notice being issued the claimant would not have such right to demand any monies

 

 

22. It is neither admitted or denied that any Default Notice in the prescribed format was ever received and the Defendant puts the Claimant to strict proof that said document in the prescribed format was delivered to the defendant

 

23. Notwithstanding point 22, I put the claimant to strict proof that any default notice sent to me was valid. I note that to be valid, a default notice needs to be accurate in terms of both the scope and nature of breach and include an accurate figure required to remedy any such breach. The prescribed format for such document is laid down in Consumer Credit (Enforcement, Default and Termination Notices) Regulations 1983 (SI 1983/1561) and Amendment regulations the Consumer Credit (Enforcement, Default and Termination Notices) (Amendment) Regulations 2004 (SI 2004/3237)

 

24. Failure of a default notice to be accurate not only invalidates the default notice (Woodchester Lease Management Services Ltd v Swain and Co - [2001] GCCR 2255) but is a unlawful rescission of contract which would not only prevent the court enforcing any alleged debt, but give me a counter claim for damages Kpohraror v Woolwich Building Society [1996] 4 All ER 119

 

 

Deed of Assignment

 

 

25. The defendant requires sight of the deed of assignment of the debt from Littlewoods to Phoenix Recoveries (UK) Ltd S.A.R.L , for the avoidance of doubt the defendant denies that there has been a valid transfer of the debt from Littlewoods to Phoenix Recoveries (UK) Ltd S.A.R.L.

 

 

Conclusion

 

26. In view of the matters pleaded above, I respectfully request that the court gives consideration to whether the claimant's statement of case should be struck out as disclosing no reasonable grounds for bringing the claim, and/or that it fails to comply with CPR Part 16.

 

27. In addition, if the claimant cannot produce a credit agreement in the prescribed form signed in the prescribed manner by debtor and creditor, the court is precluded from making an enforcement order under s127 (3) Consumer Credit Act 1974 and it is requested that the court use its powers under section 142 Consumer Credit Act 1974 to declare the agreement unenforceable and strike out the claimants case accordingly

 

.

28. Having instigated these proceedings without any legal basis for doing so, having failed to provide sufficient information required under the pre-trial protocols in order to investigate this claim, or indeed to provide a reasonable time period to investigate this matter, and having failed to investigate a dispute as required by the OFT Debt collection Guidelines I believe the Claimant's conduct amounts to unlawful harassment under section 40 of The Administration of Justice Act. Furthermore, the Claimant's behaviour is entirely vexatious and wholly unreasonable. The defendant respectfully asks the permission of the court to amend this defence when the above documents are provided by the claimant

 

 

 

Statement of Truth

 

 

I xxxxxxxxxxxx, believe the above statement to be true and factual to the best of my knowledge

 

 

Signed .....................

 

Date

 

 

 

 

This should do the trick with these maroons

[AwakeNow]

Hi there

 

sorry for not looking back in earlier,

 

no, what i mean is this,

 

 

say for example you have a debt of £1500 and say its a catalogue for example, now you miss 3 or 4 payments and go into arrears of say £500 now they should issue a default notice and follow procedure etc, at the point where they instigate legal action they should be bringing the claim for the full amount owing of £1500 NOT £500 as this is splitting one action ie £1500 into two actions and that is prohibited under section 35 of the county courts act

 

 

Hello again Paul,

 

Oh I see - 'doh' at me as Simpson says.

 

Sorry this is all new to me and not up to scartch yet with what all the abbreviations mean or the splitting of claims but now you and The Godmother have explained, its simple to see what you mean.

 

So as they have split the claim, it means its void? Would they have to put in another claim - am I now trying to run before I can even crawl... Thank you tho for the help.

 

Warm regards,

 

Maria

[AwakeNow]

Hi awake now.

 

What paul means by spliting there claims is this

 

They send you a bill for say £100.

They issue a court claim for say £50.00 plus costs.

They put on the claim we reserve the right to reclaim threw the courts any balance that is left owing. As in the £100.00

 

This is what splitting there claim means as they are just going for there costs.

 

same as paul said basically

 

 

Hello The Godmother,

 

Its a lovely sunny day here today and your p'm's cheered me lots.

 

Take care,

 

maria

[pt2537]

Hi Maria

 

what this means is they have acted unlawfully as set out within section 35

 

35. Division of causes of action.

 

 

It shall not be lawful for any plaintiff to divide any cause of action for the purpose of bringing two or more actions in one or more of the county courts.

 

so basically they have royally stuffed themselves

 

the thing is with carters , they tend to run a mile when you do defend. much of their stuff is scare tactics

 

that defence if you adapt it to your case ie enter your personal details in the blank spaces etc should have em running a mile

[AwakeNow]

This should do the trick with these maroons

 

 

Wow!

 

You certainly are very good at giving me goosebumps Paul lol.

 

Ok, I shall copy and paste, if I may, the entire legal document you have very kindly provided, thank you indeed for taking time out to help me.

 

I shall read through this now and once I got it, I shall post a copy to the court via special delivery.

 

Thank you once again : - )

[AwakeNow]

Hi Maria

 

what this means is they have acted unlawfully as set out within section 35

 

 

 

so basically they have royally stuffed themselves

 

the thing is with carters , they tend to run a mile when you do defend. much of their stuff is scare tactics

 

that defence if you adapt it to your case ie enter your personal details in the blank spaces etc should have em running a mile

 

 

Heh you read my mind paul,

 

I was going to go through the whole thing to figure out what it meant lol.

 

Thanks you are a life saver.

 

Happy Easter by the way to you ; - )

[lickthewallfatboy]

Paul-you're quite a guy!!

 

that is some defence....

[pt2537]

Paul-you're quite a guy!!

 

that is some defence....

Thanks matey,

[citizenB]

Go get em Awakenow x:)

[AwakeNow]

Heh Heh I will CitizenB - I read the defence over and over until I understood the gist of it and boy I realise how much work and effort has been put into it - its a piece of art to be honest, and don't know how to thank you all, especially Paul for the help.

 

It was sent just before Easter and the court should be perusing the papers now - hmmm, they must think I have a whole batch of solicitors working on this hee hee : )

[OLIVE.FAMILY]

Wow, you must be feeling well excited Awakenow. How does it feel to be in control of them and not the other way round !! GOOD LUCK

[AwakeNow]

Hello again Olive,

 

I am just happy that things are starting ot get sorted. I had a bad week last week and didn't do anything much apart from care for my family but this week am feeling a little more up to the task of sorting through my debts and finding appropriate letters to send to my creditors on this site.

 

Will post the court's response as soon as I get it - I have the idea they can't refuse : - )

[AwakeNow]

 

 

Just got post and Court acknowledging receipt of the wonderful defence PT2537 did on my behalf.

 

So from what I understand from the letter, the court will give a copy to Bryan Carter who will then decide if this matter of dispute can be resolved informally - maybe that means I need to buy some tea bags and offer them a cuppa @.@

 

If this matter cannot be resolved Bryan Carter has 28 days upon receipt of my defence (which adds another 5 days to the total from today as far as I can tell from cases on Consumer Forums) to tell the court to issue proceedings otherwise the case is stayed - (suspended in the vault of will he-won't he - or should that read 'she' as D.Carter's signature is the only one I have on record)!

 

Then the only time this case is in action again is when Bryan Carter applies to the the court to lift the stay.

 

Which means I have to get going with sending S.A.R.'s to all the companies involved as soon as I have the spare ten pounds for each (albeit Brayn Carter are dealing with 4 of my debtors now).

 

Heh, fun and games - hope I can do math, lol.

[pt2537]

thread moved to the legal issues forum

[NitrousOxide]

Hey PT,

Why do the courts allow such vague POC's?

That POC says "You owe some money to x, we want some".

[The GodMother]

cause they are busy and dont have all the time in the world to check everything.

 

there is always the option were if the claimant gave away to much info then we would be able to us it against them and the claimants fancy wasting time and money.

[AwakeNow]

Hello again

 

I’m back with updates : - )

 

Last week I received paperwork from Bryan Carter and they have withdrawn the case from Court - yaaaay.

 

I use ImageShack to host the images of the letters and have no idea how long they remain there.

 

http://img119.imageshack.us/my.php?image=carterletterdiscontinuagd2.jpg

 

I enclose photocopies of their Notice of Discontinuance they have stated they have sent to the court so I expect not to hear from them again – on this matter at least.

 

http://img119.imageshack.us/my.php?image=noticeofdiscontdactiontus9.jpg

 

Thanks to Paul’s brilliant legal mind in the preparation of my court defence for the above, it would seem Bryan Carter has withdrawn from taking action on another debt (again with Littlewoods) and they have written to say they have closed their file. This is in direct response in requesting a copy of the Credit Agreement with a crossed one pound postal order. They kept the £1 – I keep the letter; seems fair to me.

 

 

Meanwhile I have sent full S.A.R. (Subject Access Request) with £10 crossed postal order to Littlewoods at their very own data Protection Unit and their address if anyone needs it is:

 

Data Protection Unit Littlewoods Park Lane Netherton Liverpool L72 1LE

 

I have also sent an S.A.R. to Halifax Bank as they wish to take action against me despite there remaining a dispute over insurance they sold me and which was paid up to date at the time I was in a car accident.

 

I have to wait until end of May before finding out what happens next and am busy sorting through those files.

 

Thank you all for your help - very appreciated.

[lickthewallfatboy]

fantastic result.....well done to all concerned