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Re: Ten years of Black Horse, help me to end it please ?
Ok Susie, here we go..... Please check this over with a fine tooth comb, especially the date I've entered into the first para, insert your address details and date at the tope, as in a normal letter, include the ref. number that Aplins have used, sign and send.
I'm working on a Mac and have tried to re-format the layout but can't seem to centralise the titles...... so before you sent, please place FORMAL COMPLAINT in the middle as a header..... and centralise the subject text about CPUTR and PD-PAC. Hope that makes sense..... lol. Then send by rec. delivery to Aplins. I wouldn't hurt to send a copy to Hillesden either, so I've copied them in.
FORMAL COMPLAINT
Dear Sir/Madam,
REQUEST FOR CLARIFICATION UNDER THE CONSUMER PROTECTION FROM UNFAIR TRADING REGULATIONS (CPUTR) 2008
PRACTICE DIRECTION PRE-ACTION CONDUCT (PD-PAC)
Ref: xxxxxxxxxxxxxx
With reference to your letter of xx/xx/xx threatening legal action once again on behalf of a dubious set of clients, please note that I still do not acknowledge any debt to any of your clients or your client’s clients and refer you to back to my letter of 29th March 2014, suggesting that you re-acquaint yourself with its content. In particular, the paragraph that reads:
“Your client has already stated, in writing, that they "cannot comment on actions taken prior to acquisition" in response to two direct requests under the Consumer Protection from Unfair Trading Regulations (CPUTR) 2008 for clarification of figures sold to them by Black Horse Finance Limited some time ago. This means that your client; Hillesden Securities, are unable to substantiate any figures that they have "instructed" you to chase because Black Horse Finance themselves have been unable to substantiate any for years, before selling an alleged balance to your client.”
On the assumption that you may be experiencing some difficulties with the content of that letter, please let me assist you by highlighting what your client or your client’s clients finally admitted to after being asked repeatedly to substantiate an anomalous set of figures from Black Horse Finance under the Consumer Protection from Unfair Trading Regulations (CPUTR) 2008:
they "cannot comment on actions taken prior to acquisition"
they "cannot comment on actions taken prior to acquisition"
In an attempt to help you comprehend what your client or your client’s clients have admitted to, it refers to them not really having any idea about what they are pursuing and being unable to back anything up with any actual, cogent evidence.
In spite of this making perfect sense to me, you still appear to be struggling with it, so I now require Aplins to provide full clarification of the figures provided to them by any set of clients or client’s clients under the Consumer Protection from Unfair Trading Regulations (CPUTR) 2008 and as part of a formal complaint.
Should you attempt to follow your client’s woolly instructions in the absence of this clarification, as you have intimated, some 6 months after the last time you threatened to do it, then please note that any such litigation will be vigorously defended and I may counter claim for all quantifiable damages and costs upon having any summons set-aside, due to the dispute I have been telling you about for some considerable time and your knowledge of that dispute throughout. The court will also be made aware of your failure to comply with Practice Direction Pre-Action Conduct (PD-PAC), as well as repeated attempts by omission to mislead under CPUTR 2008.
As this matter is now the subject of a formal complaint with yourselves; Aplins, I now require a copy of your complaints procedure in response to it. I will also expect to receive a full, written response in due course which when received, will be forwarded immediately to the Financial Conduct Authority and the Solicitors’ Regulatory Authority for them to carry out their own investigations into your conduct.
Alternatively, you could always apply a dose of good old common sense and confirm back to me in writing that the matter has now been closed and referred back to your client or your clients’ clients because you fully understand the terminology that they "cannot comment on actions taken prior to acquisition" after all and as such, now realise that there is no factual definitive “balance” that can be substantiated as being outstanding to any clients or agents anywhere.
I am of course prepared to wait a reasonable length of time for you to consider your response but any additional failure to address its content properly will see complaints lodged with the aforementioned regulatory bodies anyway.
You have 14 days from receipt of this letter.
Yours faithfully,
Your Name
cc. Hillesden Securities
Ok Susie, here we go..... Please check this over with a fine tooth comb, especially the date I've entered into the first para, insert your address details and date at the tope, as in a normal letter, include the ref. number that Aplins have used, sign and send.
I'm working on a Mac and have tried to re-format the layout but can't seem to centralise the titles...... so before you sent, please place FORMAL COMPLAINT in the middle as a header..... and centralise the subject text about CPUTR and PD-PAC. Hope that makes sense..... lol. Then send by rec. delivery to Aplins. I wouldn't hurt to send a copy to Hillesden either, so I've copied them in.
FORMAL COMPLAINT
Dear Sir/Madam,
REQUEST FOR CLARIFICATION UNDER THE CONSUMER PROTECTION FROM UNFAIR TRADING REGULATIONS (CPUTR) 2008
PRACTICE DIRECTION PRE-ACTION CONDUCT (PD-PAC)
Ref: xxxxxxxxxxxxxx
With reference to your letter of xx/xx/xx threatening legal action once again on behalf of a dubious set of clients, please note that I still do not acknowledge any debt to any of your clients or your client’s clients and refer you to back to my letter of 29th March 2014, suggesting that you re-acquaint yourself with its content. In particular, the paragraph that reads:
“Your client has already stated, in writing, that they "cannot comment on actions taken prior to acquisition" in response to two direct requests under the Consumer Protection from Unfair Trading Regulations (CPUTR) 2008 for clarification of figures sold to them by Black Horse Finance Limited some time ago. This means that your client; Hillesden Securities, are unable to substantiate any figures that they have "instructed" you to chase because Black Horse Finance themselves have been unable to substantiate any for years, before selling an alleged balance to your client.”
On the assumption that you may be experiencing some difficulties with the content of that letter, please let me assist you by highlighting what your client or your client’s clients finally admitted to after being asked repeatedly to substantiate an anomalous set of figures from Black Horse Finance under the Consumer Protection from Unfair Trading Regulations (CPUTR) 2008:
they "cannot comment on actions taken prior to acquisition"
they "cannot comment on actions taken prior to acquisition"
In an attempt to help you comprehend what your client or your client’s clients have admitted to, it refers to them not really having any idea about what they are pursuing and being unable to back anything up with any actual, cogent evidence.
In spite of this making perfect sense to me, you still appear to be struggling with it, so I now require Aplins to provide full clarification of the figures provided to them by any set of clients or client’s clients under the Consumer Protection from Unfair Trading Regulations (CPUTR) 2008 and as part of a formal complaint.
Should you attempt to follow your client’s woolly instructions in the absence of this clarification, as you have intimated, some 6 months after the last time you threatened to do it, then please note that any such litigation will be vigorously defended and I may counter claim for all quantifiable damages and costs upon having any summons set-aside, due to the dispute I have been telling you about for some considerable time and your knowledge of that dispute throughout. The court will also be made aware of your failure to comply with Practice Direction Pre-Action Conduct (PD-PAC), as well as repeated attempts by omission to mislead under CPUTR 2008.
As this matter is now the subject of a formal complaint with yourselves; Aplins, I now require a copy of your complaints procedure in response to it. I will also expect to receive a full, written response in due course which when received, will be forwarded immediately to the Financial Conduct Authority and the Solicitors’ Regulatory Authority for them to carry out their own investigations into your conduct.
Alternatively, you could always apply a dose of good old common sense and confirm back to me in writing that the matter has now been closed and referred back to your client or your clients’ clients because you fully understand the terminology that they "cannot comment on actions taken prior to acquisition" after all and as such, now realise that there is no factual definitive “balance” that can be substantiated as being outstanding to any clients or agents anywhere.
I am of course prepared to wait a reasonable length of time for you to consider your response but any additional failure to address its content properly will see complaints lodged with the aforementioned regulatory bodies anyway.
You have 14 days from receipt of this letter.
Yours faithfully,
Your Name
cc. Hillesden Securities
and much quicker than I expected!! File it away safely Susie.... 
.....lol!
lol
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