licensed breeder Elizabeth Turner, Puppy farm & genetically sick pups.

[Lesley A]

I am aware of the courts potential decisions. My main aim is to recoup my losses. If and when the animal begins to suffer, I will make the necessary decisions then and no one will dictate when I should be doing so. I did not buy a dog for 'cute looks' that cause them pain like a pug etc. I purchased a normal spaniel for temperament and nature.

This forum is priceless and I appreciate the help.

The required surgery is a full fix and cheaper than maintaining him without it given the meds he will need.

A comment about other dogs not being good enough is not necessary. My claim is about this dog.

I have spent a lot of money on this dog, merely finding out what is wrong as it was not declared by the breeder in full. 

I am able to talk and deal with Judges, solicitors or anyone else I need to, at what ever level - I can communicate without issues orally.

Its written work and structuring that I struggle with.

Please can you explain where and how I can improve the document.

What is a cause of action please? Do I need to delete anything or am I adding the cause of action to the document as it stands. 

When my previous copy highlighted how the breeder breached her obligations, you said those issues were not recoverable so not necessary. I explained their presence by showing how it goes to showing her character, professionalism and attitudes to her obligations.

Exactly what do I need to do to make this document correct please and where do I place it. I am not being made aware of exactly what is missing or what needs to be removed etc.

Lesley

 

[BankFodder]

The cause of action in your case would be a breach of contract.

The contract would be whatever is written in the agreement between you – and also terms which might be implied either because it represents the reasonable expectations of both parties or because there are outside regulations such as possibly breeding rules or licence rules et cetera that are automatically incorporated into a contract for an animal. You will know this better than we do.

Why don't you start off by assembling all the bills you have incurred so far and also the professional opinions and quotations of veterinary experts.

How many pages as that run to – before I asked you to post it up in PDF format

[Lesley A]

Thank you.

I have tried again. Please re assess the document. 

I have all receipts for the costs made and prognosis reports.

I have also included the cost of another pet as a resolution of the judges opinion goes that way. When I called the courts for advice about claiming for his surgery although I had not yet paid for it, they said simply ask the judge what you want to but it has to be asked now, in the N1 form. I have now included it. 

The surgery is cheaper than his care without surgery and he has a right to live pain free - the judge may see that. I lose nothing by asking.

Jax N1 statement copy.docxJax N1 statement copy.docxJax N1 statement copy.docxJax N1 statement copy.docxJax N1 statement copy.docxJax N1 statement copy.docxJax N1 statement copy.docxJax N1 statement copy.docxJax N1 statement copy.docxJax N1 statement copy.docx

[Lesley A]

Sorry.  I will do the ODF. Version next time.  

[Lesley A]

Should I number every single paragraph or just the section dealing with the sequence of chronological events ? 

[BankFodder]

every paragraph.

It should start off:

1. the claimant agreed to buy a XXX animal from XXX defendant, a professional breeder for £XXX
2. The defendant is a licensed breeder – licensed by XXX organisation and therefore as a condition of the licence, has agreed to abide by XXX rules.
3. The claimant relied on the fact that the defendant was a licensed breeder and relied on the fact that the XXX rules would be respected by the defendant.
4. Blah blah blah
5. the defendant breached the terms of the contract in that she failed to observe the licensing rules and failed to conduct her breeding operation in compliance with the rules and failed to conduct the sale in compliance with those rules.
6. Blah blah blah

and so on

[Lesley A]

Thank you - that was helpful. Thank you.

I have not deleted the chronology but now the section previously called the Cause of Action has been implemented into the document.

Should I delete the chronology.

numbers 3 & 6 have bullet points relating to the topic within that number. Is that ok or should I give the bullet points there own number.

I basically tried to loosely structure them under her licensing breaches then the Sales Of Goods Act breaches.

Appreciated.

 

 

[Lesley A]

sorry forgot to attach.

 

Jax N1 statement cag.pdf

[BankFodder]

Started off well but then you reverted to generalisations .

You should particularize the breaches :

 Failed to do xxx contrary to the requirements of licence paragraph X sub paragraph y

Failed to do ZZ country to the requirements of licence paragraph z sub paragraph w

Etc

These should all be sub paragraphs

For instance

Paragraph 3A

Paragraph 3B

3c

3D

Etc

The paragraph letters should be in lowercase