Cabot Gaslight threat to Lift Stay

Dear MR Uppal

Re:

And:

Ref:

Claim No:

Balance:

We are writing to you regarding the above account. After our client's claim was issued, you filed a defence. So that we could provide you with the documents and information referred to in your defence, we were instructed to place your account on hold and take no further action in relation to the proceedings until our client had sent us, and we had provided you with, the information and documents requested.

The Agreement was assigned to our client by New Day Ltd RE Aqua which meant our client needed to contact New Day Ltd RE Aqua to obtain the documentation and information needed to respond to your defence. As a result, it has taken some time for us to come back to you.

This letter sets out our client's position in response to your defence and encloses the following:

• Agreement

• Statement of Account from original creditor

• Notice of Assignment

• Statement of account from our client

Your Defence

Your defence appears to be of a templated nature and does not contain any specific dispute of this claim, therefore, please find enclosed a copy of your defence for ease of reference.

Our client's position Our client's position Is set out below as relevant. to your defence:

1. It is our client's position that the particulars provide sufficient details to enable you to establish the subject matter of these proceedings. By way of background, we are instructed that this matter relates to a Credit Card with New Day Ltd RE Aqua bearing the agreement number 0003915000009327733 entered into on or around 15/03/2016 and terminated on or around 29/06/2018. Please find enclosed a copy of the agreement for your records. It is our client's position that the agreement was signed by electronic means. Our client would rely on the court's findings in the High Court matter of Bassano v Toft and Others [2014] EWHC 377 (QB) (26 February 2014). In this case Popplewell J held that:

"There is therefore nothing in the CCA to suggest that regulated agreements should not be capable of electronic signature; and I can see no reasons of policy why a signature should not be capable of being affixed and communicated electronically to an agreement regulated by the act."

2. Your reference to the Default Notice is inaccurate and misconceived. You were issued a Default Notice by New Day Ltd RE Aqua in a letter sent on 03/05/2018. Our client has no statutory obligation to provide you with a copy of the Default Notice and has fully complied with its obligations regarding this matter.

3. As noted by you, the Claimant Cabot Financial (UK) Limited is not directly regulated by the Financial Conduct Authority ("FCA"). You also correctly identify the legislation upon which the Claimant relies in bringing proceedings: Paragraph 55 of the Schedule to the Financial Services and Markets Act 2000 (Exemption) Order 2001.

4. This is a topic around which much misinformation has been spread online. It is a highly complex topic and is completely outside the realm of a simple debt claim. A simplified version is that in order to bring proceedings for a debt regulated by the Consumer Credit Act 1974 (as this debt is), the creditor should be regulated by the FCA. However, where a creditor delegates the management of the accounts it owns to other FCA-regulated entities, it is entitled to rely upon the FCA authorisation of those entities, which perform all regulated activities on its behalf.

5. Cabot Financial (UK) Limited is what is known as a 'Special Purpose Vehicle' ("SPV") - it exists for the sole purpose of purchasing and holding debts, and does not carry out any other activities itself. All of the debts it owns are managed by other members of the Cabot group with full and up-to-date FCA authorisation; specifically Cabot Credit Management Group Limited and Cabot Financial (Europe) Limited. Additionally, the Claimant's solicitor Mortimer Clarke Solicitors Limited is FCA authorised. This is a common business structure in the credit industry, of which the FCA is fully aware, and to which it has raised no concerns or objections.

6. It is unclear why you believe that a non-binding County Court decision relating to a wholly different creditor would have any relevance in relation to these proceedings. It is not a 'general principle of law' that the paragraph 55 exemption cannot be applied and to suggest so is extremely misleading. There has been one case on this topic 'elating to entitles within the Cabot group; MFS Portfolio Limited v Phelan & West, That case, considered In great detail over four days of hearing in the Court 01 Appeal In 2019, held that MFS Portfolio Limited was entitled to rely upon the paragraph 55 exemption. MFS Portfolio Limited and Cabot Financial (UK) Limited operate in the same manner, both being entities within the Cabot group and both relying upon the authorisation of Cabot Credit Management Group Limited and Cabot Financial (Europe) Limited.

7. Your request for documentation under CPR 31.14 is misleading. Our client has no record of this request and has received no contact prior to you filing this defence. Furthermore, as above, our client has no statutory obligation to provide you with this.

8. We wrote to you with a Letter Before Claim dated 02/04/2022 and informed you that we are solicitors instructed in relation to an outstanding balance due to our client Cabot Financial (UK) Limited. This is regarding an agreement originating with New Day. It clearly stated that our client would like you to address the outstanding sum of £1185.17.

The Letter Before Claim included an Income and Expenditure form for completion within 14 days and said that failing to complete this would lead to court proceedings being issued. It is our client's position that you had been provided with ample opportunity to address this matter before the issuing of County Court Proceedings but failed to do so. Our client has fully complied with its Statutory obligations regarding Civil Procedure Practice Direction 16.

The Letter Before Claim clearly states that should you fail to respond our Client's instructions were to commence legal proceedings against you.

9. On 05/07/2018 the debt and agreement was assigned to our client, Cabot Financial (UK) Limited. By virtue of the assignment, our client has been assigned all rights and title to your debt, and thus is entitled to collection of the same. A copy of the Notice of Assignment was sent to you by both New Day and our client on 20/07/2018. We enclose a further copy of the Notice of Assignment that was sent to your last known address at the time of the assignment.

10. We confirm that our client was unable to serve any documents with the claim form as it was served via the Claim Production Centre in Northampton. Practice Direction 16 for documents to be attached to the particulars of contract claims does not apply to claims to be issued by this centre.

11. Your comments regarding the Deed of Assignment are misconceived. The Deed of Assignment is a confidential document between our client and the original creditor. It does not contain any personal details relating to you and is not available for disclosure.

12. Your reference to the Law of property Act 1925 is misconceived. Section 196 of the act refers to how notice should be given; section 196(1) states: "Any notice required or authorised to be served or given by this Act shall be in writing."

13. It is noteworthy that section 136 requires that notice of the assignment be given, not that it be served - the two are clearly distinguished from each other in section 196. The remainder of section 196 relates only to notices which must be served and is thus not relevant to a notice of assignment. As the notice of assignment was sent to you by regular first class post, our client has complied fully with the requirements of the Law of Property Act 1925 in giving you notice of the assignment. Your statements alleging you are entitled to the Deed of Assignment are Inaccurate and misconceived.

14. Your reference to the Bill of Exchange Act 1882 is misconceived. This is a simple debt claim and again, as you have been provided the Notice of Assignment your reference to this act is not relevant in this matter.

15. We believe your reference to Van Lynn Developments -v- Pelias Construction Co ltd [1968] is misconceived. The main issue in the Van Lynn case was what constitutes a Notice of Assignment. The comments from Lord Denning that you quote were therefore made without detailed discussion and consideration of the issue of disclosure of the Deed of Assignment.

16. We would refer you to the case of Mitchell McFarlane and Partners Ltd -v- Foremans Lt d [2002] in which it was said that "Van Lynn suggests that ... (a debtor) ... may be entitled to ask reasonable questions to ensure that he can safely pay the assignee. This would be particularly so where the Notice comes from the assignee... in such circumstances... some kind of confirmation from the assignor/original creditor may be necessary in order to achieve the requisite degree of certainty". In your case we, the assignee, sent you the notice of assignment. However, you have also been sent a letter from New Day Ltd RE Aqua advising of the assignment to our client. We further enclose a copy of this for your records.

17. Your reference to Jones v Link Financial Ltd [2013] is unclear, misconceived and misleading. That case did not discuss the Deed of Assignment directly nor set out any right for a debtor to view the Deed. That case related to whether or not an assignee was a 'creditor' pursuant to the Consumer Credit Act 1974 and the Court of Appeal found that it was, and that it was entitled to bring proceedings in its own name. The debtor's arguments and appeal were dismissed. It is the Claimant's position that the assignment is sufficiently evidenced by both assignor and assignee giving Defendant notice of the assignment (as noted above at paragraph 37).

18. To reiterate, it is our client's position that the particulars provide sufficient details to enable you to establish the subject matter of these proceedings. We have set out further details of this debt above. The balance of your account currently stands at £13415.17. This balance includes any costs incurred as a result of attempting to recover the sum owed. Please find enclosed a statement of account for your records showing payments made and a breakdown of how the balance accrued. The documentation available evidences that you entered into an Agreement with the original creditor, made use of the agreement, failed to maintain the re-payments in accordance with the Agreement, you defaulted on that Agreement and the Agreement was then assigned to our client. The documentation further evidences how the balance of £1345.17 accrued, that a balance remained outstanding at the time the debt was assigned. Our client considers you fully liable for the outstanding balance.

The way forward

We want to work with you to come to an arrangement that works for you and brings you closer to being free of this debt. Please complete and return the income and expenditure form enclosed within 21 days of the date of this letter along with any settlement proposals you would like to put forward to our client. If we don't hear from you then unfortunately the next step is for us make an application to lift the stay on proceedings.

What does lifting the stay mean?

By making an application to the Court to lift the stay we are asking the Court to restart proceedings, set directions for next steps for both parties and list the case for a hearing where both parties points will be heard and the judge will make a decision on the case. Should the Court decide in our client's favour, this may result in a County Court Judgment being obtained against you. Our client would also ask the Court for the costs that they have incurred as a result of the court action taken and these costs will be added your debt.

What do I do next?

Our client wants to work with you to settle this matter without further court action. Please complete and return the enclosed income and expenditure form within 21 days of this letter with your settlement proposals. Should you want to get in touch you can call or e-mail us, whichever suits you best. Our e-mail address is info@mortimerclarke.co.uk, if you would prefer to talk to us please contact our office on 0333 1214454 between 8:00am to 8:00pm Monday to Friday or 9:00am to 1:00pm on Saturdays.

As explained above, if we don't hear from you, or we can't reach a settlement agreement within 21 days of this letter, our client has instructed us to make an application to lift the stay on proceedings.

We look forward to hearing from you.

Yours faithfully

Mortimer Clarke Solicitors

Dear Mortimer Clarke,

Re:

And:

Ref:

Claim No:

Balance:

Thank you for your letter [DATE OF LETTER] in reference to the above account. After your client's claim was issued, I filed a defence. You claim that so that you could provide you with the documents and information referred to in your defence, we were instructed to place your account on hold and take no further action in relation to the proceedings until your client had sent us, and we had provided me with, the information and documents requested. I note that you have not provided the documents requested and the main document that you have not provided that would appear to be the basis of your claim, as without which you have no Legal Standing ('Locus Stadi') to issue a claim, would be the Debt Sale Agreement, commonly referred to as the Deed of Assignment. Your sole reliance on a Notice of Assignment gives no evidence of your Locus Standi to issue your claim.

You claim that the Void Agreement was assigned to your client by New Day Ltd RE Aqua (the 'Alleged Assingor') which meant your client needed to contact the Alleged Assignor to obtain the documentation and information you needed to respond to my defence. You claim, that as a result, it has taken some time for you to come back to me. A period of over 6 months which would seem to be an extremely long period to simply request and receive documents.

You claim that your letter sets out your client's position in response to my defence and encloses the following:

• Agreement

• Statement of Account from original creditor

• Notice of Assignment

• Statement of account from our client

The Defence

In regards to my defense, I would like to state that it was not a template and that I have specific disputes and concerns about this claim. I would like to state that it is your Particulars of Claim which appear to be lacking in detail templated in nature.

1. It is my position that the particulars of claim do not provide sufficient details of the claim and are in breach of It is contended that the Claimant is in breach of CPR 16.4 (i)(a) and (c) by not providing concise details of claim and stating if claiming aggravated damages.

In particular, the Particulars of Claim does not identify:

⦁ a. any clear summary of the facts on which the claim is based;

⦁ b. any explanation of how the amount of financial loss has been calculated;

⦁ c. any list of documents upon which the claimant intends to rely;

⦁ d. if the Claimant intends to rely on hearsay evidence;

⦁ e. any date(s) for cause of action, date of default notice, date of assignment or date of notice of assignment; and;

⦁ f. any number of the Credit Card the Claimant claims was issued by the Alleged Assingor.

I dispute the assertion made by the Claimant's Solicitors regarding the validity of electronic signatures under the Electronic Communications Act 2000. While it is true that the Electronic Communications Act 2000 allows for contracts to be concluded by electronic means, it is also important to note that the act requires that the individual signing the contract must have given their consent to use an electronic signature.

Additionally, as per the case law established in the case of "Parker v Taswell [2018] EWHC 2711 (Ch)" it was stated that the mere fact that a person has clicked on a box, or otherwise indicated assent to standard terms and conditions on a website, does not necessarily mean that they have given their informed consent to the specific terms of the contract.

2. I strongly dispute your claim that my reference to the Default Notice is inaccurate and misconceived. It is disputed that I received any Default Notice from New Day Ltd RE Aqua or your client on the date stated in your letter.

Furthermore, I would like to bring to your attention to the case of "Lomas v JFB Firth Rixson Inc [2010] EWCA Civ 1291", which established that a creditor has a statutory obligation to serve a Default Notice before commencing legal action for arrears under the Consumer Credit Act 1974. It is disputed that your client has no statutory obligation to provide me with a copy of the Default Notice and has fully complied with its obligations regarding this matter. I put it to you that in the absence of any copy of a default notice or proof of service of one, you would fail to establish any cause of action to bring your claim.

3. As noted by myself, the Claimant Cabot Financial (UK) Limited is not directly regulated by the Financial Conduct Authority ("FCA"). I not that you agree that I also correctly identify the legislation upon which the Claimant relies in bringing proceedings: Paragraph 55 of the Schedule to the Financial Services and Markets Act 2000 (Exemption) Order 2001.

I would also like to point out that as your client, Cabot Financial (UK) Limited, is not directly regulated by the Financial Conduct Authority and that, as a Special Purpose Vehicle, it does not carry out any other activities besides purchasing and holding debts, which I believe raises concerns about its legitimacy to bring this claim.

Furthermore, I would like to bring to your attention to the case of "Intrum Uk Finance Limited v B… (County Court at Sheffield (June 2022)" – Intrum lose Appeal against finding of lower court to that the Claimant is not authorised by the Financial Conduct Authority which I believe calls into question the validity of the exemption claimed by Cabot Financial (UK) Limited and highlights the importance of the FCA regulation in protecting consumers.

4. I strongly dispute your claim that the topic of FCA regulation in relation to bringing proceedings for a debt regulated by the Consumer Credit Act 1974 (CCA) is complex and outside the realm of a simple debt claim. I also dispute the statement that a creditor is entitled to rely on the FCA authorization of other entities when bringing proceedings for a debt under the CCA.

The FCA regulation of creditors is of paramount importance to ensure that consumers are protected against unfair practices and abuse of power. In this regard, the case of OFT v RBS [2013] EWCA Civ 935 clearly states that the delegation of regulated activities to another FCA-authorized entity does not relieve the original creditor of its responsibilities and liabilities under the CCA and other relevant regulations.

5. I strongly dispute your claim that Cabot Financial (UK) Limited, as a Special Purpose Vehicle (SPV) is absolved of its responsibilities and liabilities under the Consumer Credit Act 1974 (CCA) and other relevant regulations. I also dispute that the fact that the SPV's debts are managed by other members of the Cabot group with full and up-to-date FCA authorization and that the Claimant's solicitor Mortimer Clarke Solicitors Limited is FCA authorized, absolves the SPV from its responsibilities and liabilities.

The case of OFT v RBS [2013] EWCA Civ 935 clearly states that the fact that a creditor is an SPV and does not carry out any activities other than purchasing and holding debts does not relieve it of its responsibilities and liabilities under the CCA and other relevant regulations.

6. It is disputed that it is not a 'general principle of law' that the paragraph 55 exemption cannot be applied and I disagree taht to suggest so is extremely misleading. While you seek to rely on "MFS Portfolio Limited v Phelan & West", I note that the District Judge, judging the appeal, sitting in Peterborough County Court also found that MFS Portfolio Ltd had not proved the Assignment to it from the original creditor. The court also positively approved of the principle established in a European case ruling, cited in the case, that it is for the creditor to prove statutory compliance. I note this case was also held in a lower court and the ruling on FCA registration to which you refer is not binding on other courts either.

I believe that your client's lack of FCA regsistration casts doubt on their Locus Standi to issue their claim in this matter.

7. I dispute that my request for documentation under CPR 31.14 is misleading. At the time of filing of the Defence, no track had been allocated to the case and the request which appearsin the Defence is clear that you should disclose documents that you rely on in your Claim. It is disputed that your client has no statutory obligation to provide you with a documents, upon which you rely, in your claim. When your client issues a claim, a burden exists to prove that claim and provide documents upon which the claim is based.

8. It is disputed that you wrote to me with a Letter Before Claim dated 02/04/2022 and informed you that you are solicitors instructed in relation to an outstanding balance due to your client Cabot Financial (UK) Limited. As stated in the Defence, the Void Agreement between myself and New Day was void from the outset due to their non-compliance with Section 138D of the Financial Services and Markets Act 2000 and CONC 5.2A of the the Consumer Credit Sourcebook, in respect of irresponsible lending. It is dispued that there is an outstanding sum of £1185.17 as no one gives what they do not have ('Nemo dat quod non habet').

It is disputed that any Letter Before Claim and it is disputed that your client has fully complied with its Statutory obligations regarding Civil Procedure Practice Direction 16.

9. It is disputed that on 05/07/2018 the benefit of the Void Agreement was assigned (the 'Alleged Assignment') to your client, Cabot Financial (UK) Limited. It is disputed that by virtue of the Alleged Assignment, your client has been assigned all rights and title to your debt, and thus is entitled to collection of the same. It is disputed that a copy of the Notice of Assignment was sent to you by both New Day and your client on 20/07/2018. It is disputed that a further copy of the Notice of Assignment that was sent to your last known address at the time of the Alleged Assignment. As you will be aware that Notice of Assignment does not prove a valid legal assignment, please provide a copy of the instrument of assignment, upon which you rely.

See: (Mitchell Mcfarlane & Partners Ltd v Foremans Ltd 2002) - 'Even If I had held that notice of assignment had not been given, I do not think that this would have made any difference. As an equitable assignee Foremans could not have brought an action at law without joining the assignor, old Foremans.'

10. I note that you confirm that your client was unable to serve any documents with the claim form as it was served via the Claim Production Centre in Northampton. While Practice Direction 16 for documents to be attached to the particulars of contract claims does not apply to claims to be issued by this centre, it is the responsibility of the claimant to ensure that the claim form and any accompanying documents are properly served in accordance with the Civil Procedure Rules.

In relation to the Deed of Assignment, the court may require the production of this document in order to determine the validity of the assignment and the claimant right to bring the claim. In the case of Barclays Bank Plc v O'Brien [1994] 1 WLR 277, it was held that a party claiming to be a creditor is under an implied duty to produce any document which shows that the debt was assigned to them if the assignment is in dispute.

11. It is disputed that my comments regarding the Deed of Assignment are misconceived. Pursuant to the Civil Procedure Rules, a party may be required to disclose any document that is relevant to the proceedings. In the case of Hounslow LBC v Powell [2011] EWCA Civ 8, it was held that a party cannot rely on a confidentiality agreement to resist the disclosure of a document if that document is relevant to the proceedings. The fact that you claim that the Deed of Assignment does not contain any personal details relating to me and is not available for disclosure, leads me to conclude that you either don't have a Deed of Assignment or the document, upon which you rely, is invalid as an instrument of Legal Assignment.

12. It is disputed that my reference to the Law of property Act 1925 is misconceived. Section 196 of the act refers to how notice should be given; section 196(1) states: "Any notice required or authorised to be served or given by this Act shall be in writing.". I dispute that any notice in writing has been served in this matter as required under Section 136 and Section 196 of the Law of Property Act 1925.

13. It is not a point of dispute that section 136 requires that notice of the assignment be given, not that it be served - the two are clearly distinguished from each other in section 196. it is not disputed that the remainder of section 196 relates only to notices which must be served and is thus not relevant to a notice of assignment. It is disputed that the notice of assignment was sent to you by regular first class post. It is disputed that your client has complied fully with the requirements of the Law of Property Act 1925 in giving you notice of the assignment. It is disputed that statements alleging you are entitled to the Deed of Assignment are Inaccurate and misconceived.

See: (Van Lynn Developments v Pelias Construction Co Ltd [1969] 1 QB 607 Where Lord Denning MR said: 'After receiving the notice, the debtor will be entitled, of course, to require a sight of the assignment so as to be satisfied that it is valid, and that the assignee can give him a good discharge.'

14. I am unable to find anyy reference to the Bill of Exchange Act 1882 in my Defence and therefore dispute that it is misconceived. It is disputed that this is a simple debt claim and again, as I have been provided the Notice of Assignment. Notice on it's own DOES NOT prove a Legal Assigment:

See; [Jones v Link Financial Ltd (2013) ] 1 WLR 693 Where it was found that three conditions for the validity of a LEGAL assignment must be satisfied, 'namely': that the assignment was absolute and not by way of charge; that it was in writing under the hand of the assignor, and that express notice in writing had been given to the debtor.

15. It is disputed that my reference to Van Lynn Developments -v- Pelias Construction Co ltd [1968] is misconceived. It is not disputed that the main issue in the Van Lynn case was what constitutes a Notice of Assignment. It is agreed that the comments from Lord Denning that you quote were therefore made without detailed discussion and consideration of the issue of disclosure of the Deed of Assignment, but those comments were reinforced by a more recent case:

And; (Promontoria (Oak) Ltd v Emanuel & Others 2021 EWCA Civ 1682) 52. 'we agree with Lord Denning that he is entitled to satisfy himself that there has been such an assignment';

16. It is disputed that the case of Mitchell McFarlane and Partners Ltd -v- Foremans Lt d [2002] in any way assists your client in this matter. It is not disputed that is was said that "Van Lynn suggests that ... (a debtor) ... may be entitled to ask reasonable questions to ensure that he can safely pay the assignee. This would be particularly so where the Notice comes from the assignee... in such circumstances... some kind of confirmation from the assignor/original creditor may be necessary in order to achieve the requisite degree of certainty". It is disuted that in my case you, the Alleged Assignee, sent you the notice of assignment. It is disputed that I have also been sent a letter from New Day Ltd RE Aqua advising of the Alleged Assignment to your client.

See: (Mitchell Mcfarlane & Partners Ltd v Foremans Ltd 2002) - 'Even If I had held that notice of assignment had not been given, I do not think that this would have made any difference. As an equitable assignee Foremans could not have brought an action at law without joining the assignor, old Foremans.'

17. It is disputed that my reference to Jones v Link Financial Ltd [2013] is unclear, misconceived and misleading. Whiel it is important to note that Jones v Link Financial Ltd [2013] EWCA Civ 1468 only dealt with the issue of whether an assignee was a "creditor" under the Consumer Credit Act 1974, and did not specifically address the issue of a debtor's right to view the Deed of Assignment.

However, it is well established in English law that a debtor has the right to request and view documents that evidence the assignment of their debt. In Barclays Bank Plc v O'Brien [1994] 1 WLR 277, it was held that a debtor has the right to inspect any document which contains personal information about them and which is relied on by the creditor in order to prove the debt. This principle was also upheld in Hounslow LBC v Powell [2011] EWCA Civ 8, where the court held that a debtor has a right to view the Deed of Assignment as it contains personal information about them and is relied on by the creditor to prove the debt. Therefore, it is the debtor's right to request and view the Deed of Assignment and the Claimant cannot deny the debtor access to this document.

It is disputed that the assignment is sufficiently evidenced by both Alleged Assignor and Alleged Assignee giving Defendant notice of the assignment and it is disputed that either have given notice in this case.

18. Your assertion that the particulars provided are sufficient to establish the subject matter of these proceedings is incorrect. It is the my position that the Claimant has failed to properly disclose the nature of the Void Agreement and the chain of assignments leading to your client's alleged ownership of the debt. I rely on the case of Barclays Bank Plc v O'Brien [1994] 1 WLR 277 in which the court held that a failure to disclose the chain of assignments in a debt claim is a material irregularity and renders the claim form invalid. Additionally, I rely on the case of Hounslow LBC v Powell [2011] EWCA Civ 8 in which the court held that a debtor has a right to inspect the Deed of Assignment and any other documentation used by the Claimant to establish their ownership of the debt. I requests that your client provides such documentation in order to properly establish the chain of assignments and the nature of the Void Agreement.

It is disputed that the balance of my account currently stands at £13415.17. It is disputed that the documentation your have provided so far, evidences that you entered into the Void Agreement with the original creditor, made use of the agreement, failed to maintain the re-payments in accordance with the Void Agreement, defaulted on that Agreement and the benefit of the Void Agreement was then assigned to your client. It is disputed that the documentation further evidences how the balance of £1345.17 accrued. It is disputed that a balance remained outstanding at the time the debt was assigned. It is disputed that I am fully liable for the outstanding balance, it is disputed that there is any outstanding balance.

The way forward

In order to save wasted court time and costs, I would advise your client to discontinue proceedings, close any account and delete information that they are storing on me in breach of GDPR regulations and the Data Protection Act 2018.

What does lifting the stay mean?

If you proceed in applying to lift a stay in proceedings, I will oppose any such application.

Kind Regards,

Mr Uppal