Can you please show us the Particulars of Claim (PoC) as that will determine the defence required.
Regard in the Claim issued on 24th November 2024, if you have already submitted the AoS, then you had until 4pm on Friday 27th December 2024 to submit your defence. If you have not yet done so, you are extremely likely to receive a CCJ by default.
If you have not yet submitted a defence, I suggest you immediately submit one right now. Whilst I would never suggest you use the MCOL web form to submit your defence, you do not have the luxury of time to waste. DCB Legal can press the button any time after the defence deadline has passed and get a default CCJ with no other human intervention.
You do not have time to submit anything else and because the MCOL form removes all formatting and is limited to 122 lines of 45 characters, including spaces and punctuation, here is a very basic defence you can submit by copying and pasting:
1. The Defendant denies liability for this claim.
2. The Particulars of Claim are woefully inadequate and fail to comply with CPR 16.4. As such, the Defendant is unable to provide a properly pleaded defence.
3. Specifically, the Particulars of Claim fail to:
(a) include or detail the alleged contract, breaching CPR PD 16.7.5;
(b) specify the exact wording of the contractual terms allegedly breached;
(c) specify where, when, or how long the alleged breach occurred;
(d) clearly set out a breakdown of the claim, including parking charges, damages, or interest calculations;
(e) clarify whether the Defendant is being pursued as the driver or the keeper.
4. The lack of detail in the Particulars of Claim leaves the Defendant unable to understand the case or prepare a defence.
5. The Defendant requests that the claim be struck out pursuant to CPR 3.4(2)(a) on the grounds that the Particulars of Claim disclose no reasonable grounds for bringing the claim.
6. In the alternative, the Defendant requests that the Claimant be ordered to provide complete and particularised Particulars of Claim that fully comply with CPR 16.4 in all respects.
