Complying with CPR 16.5 and CPR 3.4(2) HELP

[The Mould]

Thank you

 

In the application to court he has stated part of our Counter-claim is fraudulent (£5,000 for loss of earnings from letting the room). This is because he believes we need PP to do B&B in our own home. So he is asking the court to strike out our defence and counter-claim.

We have a court date for this special hearing on the 15/01/14, but the court hearing fee has to be paid by the Claimant by 4pm 14/01/14.

 

 

“Thank you

 

In the application to court he has stated part of our Counter-claim is fraudulent (£5,000 for loss of earnings from letting the room). This is because he believes we need PP to do B&B in our own home. So he is asking the court to strike out our defence and counter-claim.

We have a court date for this special hearing on the 15/01/14, but the court hearing fee has to be paid by the Claimant by 4pm 14/01/14”.

You simply need to counter – argue the above, by stating that the Claimant holds no standing or authority to plead this point, only the local authority hold standing to bring an action on the same, and it should be noted that the local authority has not commenced any action against the Defendant in relation to the above-stated allegation made by the Claimant..

The allegation as regards fraud being committed by the Defendant, is , therefore, groundless and denied and the Claimant is put to the strictest of proof as to his standing before this Court or indeed any Court in England and Wales on this particular matter and put to further proof as regards establishing the same.

Further to the above, this Court should note that the Claimant is not employed by the local authority. In this respect, the Claimant’s application to strike out the Defence is clearly groundless and without merit and this Court is respectfully requested to dismiss the same on the grounds of the irrefutable facts stated herein.

Kind regards

The Mould

[The Mould]

Further to the above, if builder complains that you needed planning permission for the works carried out by him, then builder has carried out such works unlawfully!

 

 

Kind regards

 

 

The Mould