Defence and Counterclaim
Claim number
D6DL60K0
Claimant
JC International Acquisition LLC
Defendant
Mr Daniel Johnson
How much of the claim do you dispute?
I dispute the full amount claimed as shown on the claim form.
Do you dispute this claim because you have already paid it?
No, for other reasons.
Defence
The amount claimed in this action relates to the installation /
upgrade of my telephony / broadband services as ordered from
TalkTalk (who had been my telephony supplier for approximately a
decade) nearly five (5) years ago.
Once installed the broadband / telephony service provided was
intermittent, and when the broadband worked - it was slower than
the previous broadband provided by TalkTalk.
TalkTalk's customer service at this time were notorious for their
appalling performance - and I appear to have been no exception.
I was completely unable to have any sensible discussions about
this issues with TalkTalk, whose call centres were entirely
overseas and who were staffed by people who had difficulty with
understanding English.
After several weeks of seeking to resolve the issue, I issued an
ultimatum to TalkTalk indicating that they were in contractual
breach (in terms of not providing me with a satisfactory / working
telecom service), and that if they could not resolve the position
I would accept their breach and terminate the contract.
No satisfactory response having been received (and with two people
seeking to run a business using that broadband), I had (of
necessity) to terminate the agreement, and take service from an
alternate supplier.
That supplier indicated they were able to see the problem (badly
connected wires at the street box), and corrected the problem.
upgrade of my telephony / broadband services as ordered from
TalkTalk (who had been my telephony supplier for approximately a
decade) nearly five (5) years ago.
Once installed the broadband / telephony service provided was
intermittent, and when the broadband worked - it was slower than
the previous broadband provided by TalkTalk.
TalkTalk's customer service at this time were notorious for their
appalling performance - and I appear to have been no exception.
I was completely unable to have any sensible discussions about
this issues with TalkTalk, whose call centres were entirely
overseas and who were staffed by people who had difficulty with
understanding English.
After several weeks of seeking to resolve the issue, I issued an
ultimatum to TalkTalk indicating that they were in contractual
breach (in terms of not providing me with a satisfactory / working
telecom service), and that if they could not resolve the position
I would accept their breach and terminate the contract.
No satisfactory response having been received (and with two people
seeking to run a business using that broadband), I had (of
necessity) to terminate the agreement, and take service from an
alternate supplier.
That supplier indicated they were able to see the problem (badly
connected wires at the street box), and corrected the problem.
In then appears that TalkTalk sold this debt and I have been
dealing with the debt owner since that date.
They have been repeatedly told that the debt is disputed, and
their own records are hugely defective, but they are merely a debt
collection operation and take no account of that point.
For example, their claim refers to my agreeing to pay in monthly
instalments - which is simply incorrect and no doubt arises from
uniform wording being used multiple claim forms.
Even to the last, I have sought to deal with this issue, even to &
including the point at which they instructed a solicitor whose
servers reject emails (Evidence to be provided).
I completely dispute that anything is due, and hereby seek to
claim my full wasted time costs & disbursements under County Court
Rules, the basis for which and details of - I will produce to the
County Court as / when / if this matter is heard.
The claimant should note that I am a Solicitor with my own London
based practice, and that my professional time is charged at GBP
£375 (plus VAT).
dealing with the debt owner since that date.
They have been repeatedly told that the debt is disputed, and
their own records are hugely defective, but they are merely a debt
collection operation and take no account of that point.
For example, their claim refers to my agreeing to pay in monthly
instalments - which is simply incorrect and no doubt arises from
uniform wording being used multiple claim forms.
Even to the last, I have sought to deal with this issue, even to &
including the point at which they instructed a solicitor whose
servers reject emails (Evidence to be provided).
I completely dispute that anything is due, and hereby seek to
claim my full wasted time costs & disbursements under County Court
Rules, the basis for which and details of - I will produce to the
County Court as / when / if this matter is heard.
The claimant should note that I am a Solicitor with my own London
based practice, and that my professional time is charged at GBP
£375 (plus VAT).
Signed
I am the Defendant - I believe that the facts stated in this form are true
Dan R. Johnson
08/05/2017
Defendant's date of birth
23/11/xxxx
Address to which notices about this claim can be sent to you
24 Bemish Road
Putney
London
SW15 1DG
Telephone number
0333 390 3525
Fax number
0871 264 9515
DX number
N/a
E-mail
Contact@EquitableLaw.com
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