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hi UK Justice .. the VSO case has now gone to Allocation Questionnaire

 

Customer Question

hi UK Justice .. the VSO case has now gone to Allocation Questionnaire stage... and my questions are ordered against the sections in that document

A : Settlement:

VSO has refused my offer of mediation. At this stage, I would rather go to Court. However, my feeling is that I should say YES to mediation (cos I don’t have the impression that they would use it to understand better and because they will say NO… and that puts me in a better position?

B: Location of Hearing
Northampton County Court is fine (because every single person with whom I have dealt in this case is connected to VSO, they can call many witnesses – I cannot. So they are less likely to get witnesses to travel to Northampton than if it is in London (where we both reside)

C: Track
YES to Small Claims (I suspect that VSO, who have money and are using expensive lawyers, may wish to move it to a higher court. They may say it is too complex etc. But my guess is that it is unwise to say YES to Small Claims and then fill in a box which says ‘If No, please say why?’ with a message such as The Claim is simple and for a low value

D: Witnesses
Will it count against me if I say ONE and s/he does not show up? And if I say ONE, and two can come? It would depend on the date of course… and I could only get a character witness, or maybe someone who occasionally works for VSO but is not beholden to them.

 

Optional Information:
System of Law: England-and-Wales

Already Tried:
it is the previous VSO case which we have been working on together thanks

Submitted: 300 days and 18 hours ago.
Category: UK Law
Value: £22
Status: CLOSED

Accepted Answer

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Expert:  UK-Justice replied 300 days and 16 hours ago.

Thanks for your question. Please remember to rate my answer SMILEY FACE OR ABOVE so that I am credited for my time.

A. Always say yes to mediation. Then if you win you can always say the other side was unreasonable if they refuse mediation.

B. If you are Claimant in person and the Defendant is a business then it will be at your Court.

If the Defendant is in person, it will be transferred to his home court.

C. Yes small claims. Put claim will take 1/2 day and low value (below £5000)

D. No - it wont count against you. It is only for case management purposes only.


Please remember to click *** SMILEY FACE *** or above so that I am credited for my time. Thank you.

Important: If you feel the need to rate as one of the lower two scores, it counts as negative feedback so please reply to me via the REPLY with any further questions you may have. I will be happy to assist you further.

Expert TypeBarrister
Category: UK Law
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Answered: 6/28/2012

Experience: Called to the Bar in 2007

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Customer replied 300 days and 11 hours ago.

For UK Justice Only:

thanks - great that I can ask for the Location to be in Bath or in Manchester, and invite witnesses from there! Here are my remaining questions for this stage: (no rush, I won't get to act on it before Monday anyway!)


E: Experts
Would it be possible/useful/credible to include a report from a Counselor I have been seeing, to help me deal with the stress of taking a professional relationship and a personal relationship (with the manager who refused my fee) of 13 years to Court?
F: Hearing
G: Other Information
I could ask for all VSO written communication about the case between the manager (ex-lover, who refused my fee) and the Company Secretary (the lawyer who took forward the case)… because I know that there are lies and inaccuracies in this… I somehow doubt that they would provide it. Is it worth asking? And if I do, are they likely to come back to me and ask me for lots of details too?
Otherwise, I suggest I leave this blank, if I have to prepare a case only two weeks before the Hearing (under Directions)… my only alternative would be to refute their Defence… Is it better to do this now or later?

H: Fee – do I enclose a cheque in the envelope to the Court for the 40 pounds? thanks

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Expert:  UK-Justice replied 300 days and 3 hours ago.

E. No - this is not the type of expert the court means.

G. Normally leave this blank

H. Yes - payable to HMCTS



Please remember to click
*** SMILEY FACE *** or above so that I am credited for my time. Thank you.



Important:
If you feel the need to rate as one of the lower two scores, it counts as
negative feedback so please reply to me via the REPLY with
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Expert:  UK-Justice replied 297 days and 10 hours ago.

I'm just following up with you to see how everything is going. Did my answer help?

UK-Justice

Customer replied 295 days and 20 hours ago.

E: Experts


thanks UK Expert


if it is not useful/credible to include a report from a Counselor I have been seeing, to help me deal with the stress of taking a professional relationship, what sort of expert will be useful?


for example, I could get a professional reference from someone for whom I have worked, but they would not have any idea of the case?


or I could try to get someone who knew of the tensions between VSO UK and VSO Netherlands, which led to some of the poor management... (I was managed by both of them) ... is this stronger? and would this person comprise an 'expert witness' because she has also worked in the sector of humanitarian development for many years, and worked for VSO UK and VSO NL? thanks Dave

Accepted Answer

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Expert:  UK-Justice replied 295 days and 18 hours ago.

Generally you would not need an expert - this is a contractual dispute.

You could take references with you yes. Or people you has worked for before.


Please remember to click *** SMILEY FACE *** or above so that I am credited for my time. The question does not close and you can ask follow ups.

Important: If you feel the need to rate as one of the lower two scores, it counts as negative feedback so please reply to me via the REPLY with any further questions you may have. I will be happy to assist

Expert TypeBarrister
Category: UK Law
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Answered: 7/3/2012

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Customer replied 295 days and 10 hours ago.

for UK Justice only: I have enlisted someone who, like me, has worked for 20 years in the humanitarian development sector at a senior level and for both VSO Netherlands and for VSO UK (she is Dutch)- the two organisations supposedly working together in this bid , who both provided a manager for me to report to, and who were at loggerheads - who can give their experience of this acrimony, can say that she passed on this work to me because she believed in my ability to do it (we have worked a little together) and can give a character reference as to my honesty (there are some falsehoods being peddled by VSO so this might be important)... do I describe her as a witness or an expert witness?

Accepted Answer

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Expert:  UK-Justice replied 295 days and 4 hours ago.

Witness.


Please remember to click *** SMILEY FACE *** or above so that I am credited for my time. Thank you.

Important: If you feel the need to rate as one of the lower two scores, it counts as negative feedback so please reply to me via the REPLY with any further questions you may have. I will be happy to assist you further.

Expert TypeBarrister
Category: UK Law
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Customer replied 293 days and 16 hours ago.

For UK Justice only


Dear UK Justice ... i have been told that I am to receive a letter from VSO which reads 'As you have decided to issue legal proceedings against VSO, it is no longer appropriate to maintain a contractual relationship with you... We refer to the VSO Trainer Contract... 'any party is entitled to terminate for any reason... this is a termination letter'


my questions are (i) is this legal? it seems to me that VSO is victimising my pursuance of my legal rights (in a fundraising job) by punishing me in a different sphere of my work for them (training)


(ii) can I use this rather heavy-handed approach as evidence in my court case (which I can back up with a witness who has suffered similar treatment of being expelled for questioning the legitimacy of a contract)


This is the letter I am expecting to use as a response - do you think it would help my case? and is it ok to share with fellow trainers?



Dear Ms Gordon (via Tricia Owens, as you request)


 


I have just opened a letter from you telling me that VSO has terminated my Trainer Contract because ‘any party is entitled to terminate for any reason’. it never did seem like a fair way to write a contract, and in this case it rather suggests victimization of a less powerful entity (me) seeking their rights – hardly the actions of a social justice or development organization!


 


It seems sad to me that VSO’s preferred language seems to be a rather high-handed and legal language, and that the organization’s current management is prepared to lose a good Trainer (as you will find from participants’ evaluations over the last five years) simply because you object to someone seeking their legitimate rights. As you may know, I have worked for VSO over a period of 13 years, in seven countries and seven roles – always to the best of my ability, always in good faith and always to positive evaluations. I take VSO’s values seriously; in contrast, this action certainly does not suggest those values or any of the rhetoric of VSO's strategy paper ‘People First’.


 


I have indeed issued legal proceedings against VSO, because it owes me money for work done more than one year ago in good faith and challenging circumstances. The reasons for refusing this money appear to be a dubious blurring of personal and professional relationships, and a refusal to accept or even investigate organizational malpractice and mismanagement. After seven requests to talk were refused (the normal way that normal people in the NGO sector do business), the very first action of VSO’s senior management on taking over the case was to issue me a legal letter from solicitors, instead of picking up the phone and having a genuine discussion. I was then offered a 25 minute meeting where VSO’s representative mostly talked at me, rather than trying to gain an understanding of multiple failures of VSO management in a poorly planned piece of work. Since that time, VSO has refused – and continues to refuse - several requests for mediation.


 


Since VSO’s refusal to pay for the outstanding 25% of my work, I have conducted 7 pieces of work for VSO as an evaluator, a trainer and a marker of academic scripts. I understand that organizations have different personalities and different departments; I have been assiduous in maintaining a professional distinction between different pieces of work, and have received excellent feedback for each of them work, without once referring in them to the ongoing dispute over VSO’s financial debt to me.


 


VSO has crossed that line – despite previously telling me that it wanted me to continue my good work for the organization – in spreading a dispute from one piece of work to my entire relationship with the organization.


 


May I ask a question? Should the law of the land say that it is correct and lawful to be paid for the work I have done, will VSO continue to bar me from training? And would that indicate, once more, a refusal to accept, investigate or listen to a supportive but challenging voice? I am quite able to represent VSO values in training, marking academic scripts, evaluations, management etc despite an individual difference of opinion on one piece of work… my challenge to the organization is whether it is capable of doing the same.


Yours sincerely


Dave Hampson


 






thanks


Dave

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Expert:  UK-Justice replied 293 days and 16 hours ago.

They can terminate if the contract allows for it.

No clause, no termination.

Yes you can use the letter

But it is only relevant if it goes to a matter in dispute between the parties.

If it goes to the heart of the dispute then you can exhibit it to a statement.


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Customer replied 293 days and 16 hours ago.

thanks UK-J


My view is that the letter displays the kind of high-handed treatment, and unwillingness to listen or investigate issues of malpractice / mismanagement, which has led to their dissatisfaction with the proposal (and for which they have, rather than take these issues on board, simply tried to scapegoat me as the sole cause and the sole person to be penalised) .. do you think that stands up?

and what is 'exhibit it to a statement' please? I was planning to use it in my submission to the court as part of a number of lines of attack such as (i) inadequate time given (ii) financial information refused (iii) inadequate management (eg changing of submitting entity and of countries mid-contract) etc etc




Accepted Answer

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Expert:  UK-Justice replied 293 days and 15 hours ago.

It may be persuasive but not conclusive.

You have a statement and you say I received the following letter dated.

I exhibit it as item 1


Please remember to click *** SMILEY FACE *** or above so that I am credited for my time. Thank you.

Important: If you feel the need to rate as one of the lower two scores, it counts as negative feedback so please reply to me via the REPLY with any further questions you may have. I will be happy to assist you further.

Expert TypeBarrister
Category: UK Law
Pos. Feedback: 96.4 %
Accepts: 10295
Answered: 7/5/2012

Experience: Called to the Bar in 2007

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Customer replied 292 days and 23 hours ago.

For UK Justice


I'm now writing my case, and I have to consider how to raise the fact that the person who unilaterally refused to pay me (except for 25%) was a lover of mine 12 years ago, after which we had an estranged relationship (she wanted marriage and children, I didn't) ... i asked her whether we could work together before taking the job and she said 'yes, it's professional'... I know there was SOME influence becasue of this because her answer to me, to refuse me the first time, was very strange - the first criticism I received of my work - and because she refused my receipts, but when I re-submitted them in virtually the same way (but with extra receipts I had forgotten) they were approved by someone else without question.


How do you think I should include this information in my submission? As central or peripheral? thanks

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Expert:  UK-Justice replied 292 days and 23 hours ago.

I dont think its central to the issue.


So would not be too concerned about it.

 

Please remember to rate my answer so that I am credited for my time.

 

The question does not close and you are free to ask follow up questions.

Customer replied 291 days and 15 hours ago.

hmmm, i am pretty sure that if anyone else had handled the contract, it would have been fully paid, so i do think it is central... and i think the pernickety response from my ex-lover/ manager (complaining about receipts, invoices, rates etc) shows this... i was more asking HOW to include it rather than whether...


on another point... VSO have sent me their submission to the Court (Allocation Questionnaire) ... i would have thought it's an administrative form.. do i need to send them mine? and if i don't, does it count against me? thanks.. will rate your answer on your reply Dave

Accepted Answer

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Expert:  UK-Justice replied 291 days and 14 hours ago.

No.

Its mainly for the judge.

You can do but it's not vital


Please remember to click *** SMILEY FACE *** or above so that I am credited for my time. The question does not close and you can ask follow ups.

Important: If you feel the need to rate as one of the lower two scores, it counts as negative feedback so please reply to me via the REPLY with any further questions you may have. I will be happy to assist

Expert TypeBarrister
Category: UK Law
Pos. Feedback: 96.4 %
Accepts: 10295
Answered: 7/7/2012

Experience: Called to the Bar in 2007

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Customer replied 282 days and 1 hours ago.

For UK Expert only:


In one of our previous discussions, you said:



If you are Claimant in person and the Defendant is a business then it will be at your Court.

If the Defendant is in person, it will be transferred to his home court.'


I have now received a letter from Northampton County Court allocating the case to Wandsworth, when I asked for Bath.



The letter says 'If the defendant is an individual, the claim has been transferred to the Court covering the area where the defendant lives or carries on business' ... but of course, the defendant is not an individual, it's an organisation, VSO.. although of course they are using the name of the Company Secretary.. surely this is sharp practice?


How do I appeal this decision please? I ony have a telephone number in teh Wandsworth Court.. I could easily find the one for Northampton... or is it best done by mail?


THis is important as I have a key witness who has agreed to appear if the case is heard in Bath


thanks Dave



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Expert:  UK-Justice replied 282 days ago.

Yes you can appeal the decision.

If you are a claimant Then it will be held at your home court.

Yes you an appeal the decision, but if you appeal and lose then you would be liable for the appeal costs.

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Important: If you feel the need to rate as one of the lower two scores, it counts as negative feedback so please reply to me via the REPLY with any further questions you may have. I will be happy to assist

Customer replied 282 days ago.

hi UK Justice... how (mail, phone?) and where (NOrthampton? Wandsworth?) do I appeal.. and what are the costs? I don't want it at my 'home court' but at the court which my witness can attend, in Bath... thanks Dave

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Expert:  UK-Justice replied 281 days and 23 hours ago.

You need to fill out an appeal form on n161

The cost is £100

You need to appeal to the court which the claim has been transferred to.

Please remember to click *** SMILEY FACE *** or above so that I am credited for my time. The question does not close and you can ask follow ups.

Important: If you feel the need to rate as one of the lower two scores, it counts as negative feedback so please reply to me via the REPLY with any further questions you may have. I will be happy to assist

Customer replied 281 days and 22 hours ago.

I just called the court and they were helpful and said just to send a letter to the District Judge.. so I'll try that first, thanks.. is there any honorific title or anything else i should add? thanks Dave

Accepted Answer

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Expert:  UK-Justice replied 281 days and 21 hours ago.

Dear judge

That's it.

Please remember to click *** SMILEY FACE *** or above so that I am credited for my time. The question does not close and you can ask follow ups.

Important: If you feel the need to rate as one of the lower two scores, it counts as negative feedback so please reply to me via the REPLY with any further questions you may have. I will be happy to assist

Expert TypeBarrister
Category: UK Law
Pos. Feedback: 96.4 %
Accepts: 10295
Answered: 7/17/2012

Experience: Called to the Bar in 2007

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Expert:  UK-Justice replied 277 days and 10 hours ago.

I'm just following up with you to see how everything is going. Did my answer help?

UK-Justice

Customer replied 264 days and 15 hours ago.

N161:


hello UK Justice, I hope you are doing well...


If you remember, on the Small Claims track, I asked for the Court to be Bath, because this was the only place my witness (who has two small children) could attend. My understanding - which seemed to be confirmed by literature from the Northampton Court - was that as the Claimant, my choice of Court would be respected AS LONG AS the Defendant was a business, not an individual.


When the notice came back from Northampton, the chosen Court was round the corner from VSO (the Defendant). This bothers me because VSO is represented by a practising lawyer who works in Wandsworth... the Judge Swan is a practicing lawyer who works in Wandsworth...




I wrote a letter contesting the decison. Today I got a reply 'Informal request by letter to transfer the case to Bath is rejected because the Defendant is sued as an individual and no explanation of the nature of the key witness' evidence or why he/she cannot attend in Wandsorth is given by the Claimant. The Claimant may renew his request for transfer by formal application on notice, supported by evidence'




The latter part is true; i did not know that i needed to give explanations as to witness' evidence, or why she could not attend Wandsworth.




The former part is preposterous... Surely it cannot be claimed that VSO is an individual just because there is a person's name used? I am suing VSO. I was told by VSO that their Company Secretary - the lawyer - would represent them in the case, so I put her name to make sure my letter got to the right person. Of course I am not suing her as an individual.




Am considering N161 and paying 100 pounds or thereabouts.. the 'formal application'.




Do you know if the same Judge who decided not to allow my 'informal appeal' will have to re-consider his decison, or does somebody new do that?




And what chance to I have of convincing them that the Court should be paid (the witness has knowledge of teh disputes between my two 'bosses' in VSO NL and VSO UK, and she has worked for both organisations... she knows me well, and knows the humanitarian sector (the job was fundraising in East Africa for two (warring) VSOs; NL and UK)




Thanks




Dave

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Expert:  UK-Justice replied 264 days and 15 hours ago.

If D is an individual (even if business) then it will be transferred to his home Court.

So check this before you do anything.


Please remember to click *** OK SERVICE *** or above so that I am credited for my time. The question does not close and you can ask follow ups.

Important: If you feel the need to rate as one of the lower two scores, it counts as negative feedback so please reply to me via the REPLY with any further questions you may have. I will be happy to assist you further.

Customer replied 264 days and 15 hours ago.

it is not an individual.... it is Voluntary Service Overseas... there is an individual who is representing them, called Ms Owens, and so the Defendant is named as Ms Owens, VSO ... but surely it cannot be claimed that an organisation is an individual?

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Expert:  UK-Justice replied 264 days and 14 hours ago.

Why did you name him and not the VSO.

Customer replied 264 days and 14 hours ago.

we discussed it, and it was what you advised me to do (sorry to say it bluntly.. i am sure that these things could go a different way, but that is what happened...)

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Expert:  UK-Justice replied 264 days and 14 hours ago.

I explained if you sue an organisation then as claimant it will be transferred to your home court.

If you sue an individual it will transfer to their court.

You have named an individual - you should have named the organisation, that is why the transfer to D court has taken place.

You can make an application to have it transferred to your court.

Explain to the judge in a statement above and see if they will agree To transfer.

But this must be a formal application, you need to explain the role of the person you are suing,

But if they are named in person I think you will be stuck.


If you were partners but weren't married or civil partners
If you weren't married or registered civil partners, you won't automatically get a share of your partner's estate if they don't make a will.
If they haven't provided for you in some other way, your only option is to make a claim using certain legislation. You can make a claim under the Inheritance (Provision for Family and Dependants) Act 1975. There is a useful tool you can use on the HM Revenue & Customs website - see the link below.

Customer replied 264 days and 14 hours ago.

This is the letter I sent



Dear Judge


Re: my Claim Number 2QT57777


I received today a letter from Northampton (CCBC) County Court allocating my Claim Number 2QT57777 to your good Court.


The letter states that ‘If the defendant is an individual, the claim has been transferred to the Court covering the area where the defendant lives or carries on business.”


The defendant is not an individual, but an organization, a not-for-profit business.


I am an individual to whom they have an outstanding debt. It is my understanding that in this instance, the Court allocation would normally be in keeping with my needs. In this case, I have a key witness who can only attend the hearing if it is at Bath County Court, as requested in my Allocation Questionnaire.


I would very much appreciate your support in the re-allocation of this hearing to Bath County Court.


I have also written a similar letter to Northampton County Court in this regard.


Many thanks in advance.


The answer was as in my first message... re-iterating that it is an individual (it's very clearly NOT an individual) , and saying that i had not said why the person could not attend, or what evidence they would supply.


Does this same Judge look at a formal application? or is it a different one, and what chances to succeed please?


ta

Customer replied 264 days and 13 hours ago.

Is it the same Judge who said 'No' who has to review his.her own decison please?

Accepted Answer

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Expert:  UK-Justice replied 264 days and 13 hours ago.

It won't be the same judge,.

You may need to apply to amend the name of the proceedings so it is the name of the organisation only.

You could then ask for transfer as well.

B] Please remember to click *** OK SERVICE *** or above so that I am credited for my time. The question does not close and you can ask follow ups.

Important: If you feel the need to rate as one of the lower two scores, it counts as negative feedback so please reply to me via the REPLY with any further questions you may have. I will be happy to assist you further.

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Answered: 8/3/2012

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Customer replied 264 days and 13 hours ago.

ok, how do i find out if i need to amend the name of the proceedings?


do i call the Court?


and then if I do need to, how do i do this please?


do I do it in N161?


thanks

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Expert:  UK-Justice replied 264 days and 12 hours ago.

Well you said it was in the name of an individual NOT firm.

That is why.

You need form N244 and ask to amend the name and transfer proceedings.


Please remember to click *** OK SERVICE *** or above so that I am credited for my time. The question does not close and you can ask follow ups.

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Customer replied 264 days and 11 hours ago.

ok, thanks, XXXXX XXXXX found the form... I'm quite happy to give Good Answer three times if I can get answers to the below questions...


under "What order are you asking the court to make and why?"


do I write:


I wish to change the name of the Defendant from 'Ms Tricia Owens, VSO' to 'VSO'. It was my error to name an individual, believing that I would expedite the papers to the right hands. The case is in no way directed at Ms Owens, and nor would she be liable were VSO to lose it, or benefit if VSO won it.


I wish to transfer proceedings to Bath County Court. The reason for this is that my key witness has two small children and a full-time job, and is unable to find cover to travel for a 14 hour day to London. My key witness was initially offered this job and was unable to do it. She has long experience of work with both VSO UK and VSO NL, who formed the two parties managing the work. She knows of the historic disagreements and conflicts between the two organisations, of the lack of foresight in them jointly managing the project. She also knows the Claimant's reputation, his work, and his character over many years. She vouched for his capacity - under normal conditions - of the Claimant's ability to successfully conduct the work, and nothing in her understanding of the case, or its documents, has led her to alter her view. (do I need a witness statement at this stage? I believe the witness is currently in Peru, so this might be difficult... can I ask for time to get this?)


Under: Have you attached a draft of the order you are applying for? - what is this?


Under: Who should be served with this application? Is this 'VSO'?


and


What information will you be relying on, in support of your application? (tick boxes are: the attached witness statement ; the statement of case; the evidence set out in the box below) do i tick 'the statement of case' .. and then submit this 14 days before the hearing?


The initial time given was two hours.. I propose to submit the backgroudn correspondence which runs to 40 pages, and a case of about 25 pages... do you think I should ask it to be changed to three hours?


thanks


Dave

Accepted Answer

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Expert:  UK-Justice replied 264 days and 2 hours ago.

What order and why. I would simply add Tricia Ownes represents the Defendants and should be on record as acting - not as an individual to the proceedings.

Draft order - leave blank

Who should be served - Defendant

Which evidence - statement of case

Time Estimate - without a hearing so leave blank

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Important: If you feel the need to rate as one of the lower two scores, it counts as negative feedback so please reply to me via the REPLY with any further questions you may have. I will be happy to assist you further.


Expert TypeBarrister
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Pos. Feedback: 96.4 %
Accepts: 10295
Answered: 8/4/2012

Experience: Called to the Bar in 2007

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Customer replied 263 days and 23 hours ago.

thanks - re: time estimate... a 2-hour hearing has been set for 16 October... I doubt this is enough time, as I have about 25 pages of evidence and 40 of background... do you think the Judge will look kindly on a request for three hours, or is that pushing it?



When I send the N244, do I send it to the same Court (Wandsworth) [presumably not same Judge, if s/he will not reconsider her/his initial decision... and with 100 pound cheque to Wandsworth County Court?


 


If I thought it would be impossible to move it to Bath, would it be more possible to move it closer to my home, in Brixton.?


 


Many thanks, XXXXX XXXXX… I do find this baffling, and appreciate your help… as I said I will accept multiple times, sending you minor questions which won’t take up your time


 


Dave


Accepted Answer

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Expert:  UK-Justice replied 263 days and 17 hours ago.

Just send the n244 to the court.

You do not ask for a judge, you do not do anything with time estimate.

It will either be at your home court or defendant home court, not part way.

B] Please remember to click *** OK SERVICE *** or above so that I am credited for my time. The question does not close and you can ask follow ups.

Important: If you feel the need to rate as one of the lower two scores, it counts as negative feedback so please reply to me via the REPLY with any further questions you may have. I will be happy to assist you further.

Expert TypeBarrister
Category: UK Law
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Answered: 8/4/2012

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Customer replied 263 days and 16 hours ago.

so i send to Wandsworth County Court with a 100 pound cheque made out to ' Wandsworth County Court'?


the letter from the Judge at Wandsworth asked for the reasons why I wanted to have the Small Claims session at the witness' local court in Bath.


so there must be some possibility... the reality is that she can get relatives to cover 3-4 hours, but cannot get child-care for 14 hours to come to London and back. And as she is putting her neck on the line (she often works for VSO but probably would never be asked back if she defends me against them), I am very keen to transfer to Bath


what is the probability? (i) to get it transferred to Bath (ii) to get it transferred to my local court in Kennington... and can I ask for (i) as priority and (ii) if it is not possible?

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Expert:  UK-Justice replied 263 days and 15 hours ago.

£80 cheque to HMCTS.

Don't put anything. Just amend the clam name and ask for a transfer.

That's it.

B] Please remember to click *** OK SERVICE *** or above so that I am credited for my time. The question does not close and you can ask follow ups.

Important: If you feel the need to rate as one of the lower two scores, it counts as negative feedback so please reply to me via the REPLY with any further questions you may have. I will be happy to assist you further.

Customer replied 263 days and 14 hours ago.

yes.. thanks.. but do you think I have a chance of getting a transfer to Bath on the basis that my key witness is there?


or should I try for Kennington (close to my home)


or can I say my priority (i) is Bath and priority (ii) is Kennington?

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Expert:  UK-Justice replied 263 days and 14 hours ago.

On the basis of your witness then no.

It is either your home or defendant home court.

B] Please remember to click *** OK SERVICE *** or above so that I am credited for my time. The question does not close and you can ask follow ups.

Important: If you feel the need to rate as one of the lower two scores, it counts as negative feedback so please reply to me via the REPLY with any further questions you may have. I will be happy to assist you further.

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Customer replied 263 days and 12 hours ago.

ok, thanks.. but do you think it's worth asking for Bath as first priority, and Kennington as second priority? and give my reasons?

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Expert:  UK-Justice replied 263 days and 12 hours ago.

No.

It will either be your home Court or D home Court.

No others.


Please remember to click *** OK SERVICE *** or above so that I am credited for my time. The question does not close and you can ask follow ups.

Important: If you feel the need to rate as one of the lower two scores, it counts as negative feedback so please reply to me via the REPLY with any further questions you may have. I will be happy to assist you further.

Customer replied 262 days and 21 hours ago.

Hi. And if the Defendant is a business, and I am an Individual, it is me who chooses the Court. Is that right? Is it my legal right, or is it the discretion of the Judge?

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Expert:  UK-Justice replied 262 days and 21 hours ago.

You have a right of appeal.

You can appeal to the Court of Appeal criminal division.


Please remember to click *** OK SERVICE *** or above so that I am credited for my time. The question does not close and you can ask follow ups.

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Customer replied 262 days and 21 hours ago.

ok, but is it my right to choose my home Court as a Claimant Individual against a Defendant Business?



or is it discretionary?

Accepted Answer

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Expert:  UK-Justice replied 262 days and 21 hours ago.

No.

It is not your right.

It will either be your home Court or the Defendants home Court.

One or the other. You have no choice to pick a Court.


Please remember to click *** OK SERVICE *** or above so that I am credited for my time. The question does not close and you can ask follow ups.

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Customer replied 262 days and 20 hours ago.

ok... so I will fill in my form and pay 80 pounds...


in the letter which was refused by the Judge, I wrote:



I received today a letter from Northampton (CCBC) County Court allocating my Claim Number 2QT57777 to your good Court.




The letter states that ‘If the defendant is an individual, the claim has been transferred to the Court covering the area where the defendant lives or carries on business.”




The defendant is not an individual, but an organization, a not-for-profit business.




I am an individual to whom they have an outstanding debt. It is my understanding that in this instance, the Court allocation would normally be in keeping with my needs. In this case, I have a key witness who can only attend the hearing if it is at Bath County Court, as requested in my Allocation Questionnaire.




I would very much appreciate your support in the re-allocation of this hearing to Bath County Court.


 


This was not successful. What can I write which will be successful? Is it enough to write the above and say 're-allocation of this hearing to my Home Court'? Or will I be expected to give special reasons (I doubt that I can tell the truth... that I don't want a case against a Wandsworth lawyer to be heard by another Wandsworth lawyer) .. thanks


Accepted Answer

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Expert:  UK-Justice replied 262 days and 20 hours ago.

As I said you also need to apply to amend the name of the proceedings to the ORGANISATION.

Then your application should be ok.


Please remember to click *** OK SERVICE *** or above so that I am credited for my time. The question does not close and you can ask follow ups.

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Customer replied 262 days ago.

hello UK Justice


I called the Court this morning, and they encouraged me to apply for a transfer to Bath, but to suggest a fall-back position of my local Lambeth Court... good news eh?


in http://hmctsformfinder.justice.gov.uk/courtfinder/forms/n244-eng.pdf


box 3 ( What order are you seeking and why?) I now have:


'To remove the name '***' as Defendant and replace it with '***'


'To accommodate a key witness for reasons provided, to transfer proceedings to Bath County Court, and alternatively to the Claimant's home court, Lambeth County Court''


Under box 10 ('What info will you be relying on in support of your application'), I have:


'This is an application pursuant to Rule 19.2 Civil Procedure Rules to remove Miss J Owens as the Defendant and substitute with VSO. The claimant was informed by the defendant company that Miss Owens should be named in the proceedings as she represents the defendant. By mistake the claimant added Miss Owens as the defendant when her details should in fact appear as the defendants representative. This was an error by the claimant who respectfully XXXXX XXXXX it is in the interests of justice for this amendment to be made.'


The application under CPR Rule 30 'change of venue' 'special measures needed for potential witnesses to accommodate my key witnes who is:


* Key because she has over 10 years' work experience with VSO, and with both managers of this particular contract, VSO UK and VSO Netherlands, and with their relationship which is pertinent to this case. She passed this piece of work to the Claimant whose character, reputation and work she has known for over 10 years; she continues to vouch for his suitability.


* Raising two small children - alongside a busy work schedule - for whom she cannot provide 14 hours' appropriate provision to allow a trip to London.


Should a transfer to Bath be deemed unacceptable, the Claimant - as an individual facing a non-profit Defendant - respectfully XXXXX XXXXX hearing without his key witness at his local court, Lambeth County Court.


please suggest any amendments! thanks Dave



Accepted Answer

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Expert:  UK-Justice replied 261 days and 22 hours ago.

No that seems ok.

Good luck with the application.

B] Please remember to click *** OK SERVICE *** or above so that I am credited for my time. The question does not close and you can ask follow ups.

Important: If you feel the need to rate as one of the lower two scores, it counts as negative feedback so please reply to me via the REPLY with any further questions you may have. I will be happy to assist you further.

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Answered: 8/6/2012

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Expert:  UK-Justice replied 261 days and 10 hours ago.

I'm just following up with you to see how everything is going. Did my answer help?

UK-Justice

Customer replied 249 days and 22 hours ago.

For UK Justice only.. Hi UK Justice... here's proposed answers to (a) the Court and (b) VSO about VSO's wish to go to a hearing for location.. I would appreciate any edits (only the top three emails are the one's in question... below that is background...which I intend to enclose the below correspondence to the Court ... many thanks Dave


 


 


 


The District Judge,


 


Wandsworth County Court (359), 76-78 Upper Richmond Rd


 


London SW15 2SU


 


 


 


 


 


Dear Judge


 


Re: my Claim Number 2QT57777, David Hampson v Ms Owens and Voluntary Service Overseas


 


 


 


On 6 August, I submitted an application to amend the name of the Defendant by deleting Ms Owens and substituting with ‘Voluntary Service Overseas, 27a Carlton Dr, London SW15 2BS (agreed by the Defendant) and to transfer the venue of proceedings to Bath.


 


On 10 August, I requested a week’s postponement of my application being heard, because a response from the Defendant mentioned a potential ‘openness to persuasion’ to a change of venue.


 


I regret to inform you that the Defendant has not agreed to a change in venue, or to mediation of the case, although the tone of correspondence has noticeably improved.


 


In these circumstances, I would be grateful if the change in the name of the Defendant could be dealt with administratively by the District Judge, as requested in my 10 August letter, and the part of my application dealing with the venue of the proceedings be dealt with at your discretion. I have already submitted my cheque of 80 GBP for this purpose, and it has been cashed, but I would be open to either a personal or a telephone hearing.


 


I will be available in London for any potential hearing from 20-22 August inclusive, and from 4-7, 16-17 and 28-30 September. The Defendant concurs (in the attached correspondence) that a personal hearing need not take more than 15 minutes. I am also available for a telephone hearing at any time on +44 XXXXXXXXXX although calls can be more difficult to arrange outside of the UK-


 


I trust that the enclosed meets with your agreement, and would appreciate a chance to rectify any errors on the above address or XXXXX@XXXXXX.XXX .


 


In the spirit of the civil procedure rules and under your instructions to maintain contact with the Defendant, I shall continue to inform VSO of pertinent developments.


 


Many thanks in advance.


 


 


 


 


 


David Hampson


 


 


 


 


 


 


 


 


 


 


 


 


 


 


 


Dear Jonathan


 


 


 


Thanks for your tone, which is a very welcome contrast with almost all of my communications from VSO to date on this matter. Long may it continue; politeness and civility always make these distasteful experiences easier. Thank you also for your offer of help.


 


 


 


I’m sorry that your witnesses wish to contest a move to Bath, given the stated reasons, and also that you’ve been unable to reciprocate on their identity; maybe in your next email? I also regret a continued refusal of VSO to enter mediation. I do welcome, however, that you will not contest the Court’s eventual decision, and I have already completed N244 and paid the fee for a hearing (in fact, I have found the Court straightforward and helpful on all matters, rather than frustrating). I will leave it to the Court to decide whether a telephone or personal hearing is preferable.


 


Jonathan Sweet


 


I look forward to your investigation into the ‘other’ outstanding VSO debt to me of 614 GBP.


 


 


 


All the best,


 


 


 


Dave


 


 


 


From: Jonathan Sweet [mailtoXXX@XXXXXX.XXX]
Sent: Friday, August 17, 2012 11:37 AM
To: Dave Hampson
Cc: Company Secretary; Tricia Owens
Subject: RE: your potential openness to transfer


 


 


 


Dear XXXXX


 


 


 


I have now considered this with the witnesses VSO shall be calling in this matter. I feel that the most appropriate way to ensure the fairest outcome for all parties is if the court consider our respective positions. As we are both aware, we have witnesses who all have child care issues and I full respect and understand your comments below. There is also an additional cost factor involved in getting everyone involved to Bath for a 2 hour hearing. We will also lose our trial date in October if the matter is transferred to Bath.


 


 


 


While we are not consenting to your application, I can assure you that this decision has not been made with the intention of being obstructive. The court, may, after considering our positions make a decision to transfer the matter to Bath and this would not be a decision we would appeal in any way.


 


 


 


To facilitate matters, you may wish to explore the options available when making an application to the court. It is possible for a judge to consider the matter on the papers. i.e you make the application with your arguments to transfer the matter to Bath and VSO submit a letter setting out our reasons to keep the matter in London (in my view, this would be the easiest way to deal with the matter). It is also possible for the hearing to be conducted over the telephone (although, I think courts are reluctant to do this when a litigant in person is involved). Finally, it is possible to have a hearing before a judge – I feel that 15 minutes is more than sufficient to deal with this matter.


 


 


 


When making the application, you may wish to use this form:http://debtsorters.co.uk/pdfs/county_court_forms/n244.pdf . I am happy to conduct the matter in any way you wish and apologies if you are already aware of the above.


 


 


 


Finally, I have not forgotten the important issue of the £614. Typically, the individuals who I need to discuss the matter with are on holiday this week. I understand that they are returning on Monday and I have it as a priority to resolve the issue as soon as I can. In any event, I will write to you again on Monday to update you.


 


 


 


I don’t desire to make this process any more burdening on you than is necessary, so please feel free to ask me any questions relating the administrative side of dealing with the court (such as what forms to use etc) – I know from experience, that they can be a frustrating entity to deal with. It goes without saying that any assistance I may give you is not intended as advice.


 


 


 


Best


 


 


 


Jonathan


 


 


 


 


 


From: Dave Hampson [mailtoXXX@XXXXXX.XXX]
Sent: 16 August 2012 17:31
To: Jonathan Sweet
Subject: RE: your potential openness to transfer


 


 


 


Dear Jonathan


 


 


 


Thanks for the notice; I look forward to hearing from you tomorrow


 


 


 


Dave


 


 


 


From: Jonathan Sweet [mailtoXXX@XXXXXX.XXX]
Sent: Thursday, August 16, 2012 11:29 AM
To: Dave Hampson
Cc: Company Secretary
Subject: RE: your potential openness to transfer


 


 


 


Dear Mr Hampson


 


 


 


Thank you for your email.


 


 


 


I understand the time constraints in respect of your communications with the court. I will respond to your points below shortly.


 


 


 


Kind regards


 


 


 


Jonathan


 


 


 


From: Dave Hampson [mailtoXXX@XXXXXX.XXX]
Sent: 15 August 2012 13:50
To: 'Dave Hampson'; Jonathan Sweet
Cc: Company Secretary
Subject: RE: your potential openness to transfer


 


 


 


Dear Mr Sweet


 


 


 


Apologies, I don’t wish to hurry you for an answer and I know that my question is only two days old, but I asked the Court for one week’s grace whilst I explored VSO’s openness to transfer.


 


 


 


One week will pass on Friday afternoon, so I would very much appreciate any response by 14.30 on Friday, so that I can make the appropriate response to the Court.


 


 


 


Many thanks in advance


 


 


 


Dave Hampson


 


 


 


From: Dave Hampson [mailtoXXX@XXXXXX.XXX]
Sent: Monday, August 13, 2012 12:51 PM
To: 'Jonathan Sweet'
Cc: 'Company Secretary'
Subject: your potential openness to transfer


 


 


 



Dear Mr Sweet

Thanks for your email; so many of my emails to VSO on practical matters have been ignored recently that I particularly appreciate a response and your more positive and down-to-earth tone. I’m happy to receive messages from you or anyone else (although I’m a bit confused; I was specifically asked to route messages through Ms Owens when she was named as Defendant; if there’s another change, and you don’t want me to cc: her, please let me know).

[I have written to the Court to advise them that VSO is amenable to changing the name of the Defendant, providing our email exchange and asking that this matter be settled on an administrative basis.

I am encouraged that VSO is ‘open to persuasion’ on the issue of location, and I should like to explore this with you.

Like myself, my witness, Jose Sluijs-Doyle has a long history of understanding and working for VSO (in her case for both VSOI and VSO NL) and retains affection for the organization and a belief in its principles. She is in an unprecedented position of being able to untangle some of the management issues around this particular contract, and would therefore add to both the fairness and the learning potential of this hearing.

Her children are aged 3 and 5 years old. I wish to transfer proceedings to Bath County Court because although she is able to find short-term family relief, she is unable to find cover to travel for a 14 hour day to London.

I feel that there may be a qualitative difference in the nature of the witnesses; like myself, my witness is a busy professional acting as a volunteer in this case. She is prepared on her own time, and against her own financial interests ( not to represent me but) to stand up for what she believes to be the truth. You may be able to advise me as to the identity of your witnesses, and whether they are volunteering their time or are being paid their normal salary to represent VSO in court.

Whereas I would certainly want the childcare arrangements of VSO witnesses to receive adequate consideration, I do feel that the particular situation of my witness as an unpaid volunteer doing a particularly busy job should ultimately have a greater bearing on the venue’s location.

In the circumstances, to save time and costs dealing with the issue, I would be grateful for your agreement to transfer the proceedings to Bath County Court pursuant to rule 30 Civil Procedure Rules, Your agreement to this course of action may avoid an unnecessary hearing to determine the issue.

Many thanks for investigating the failure of VSO’s promised payment of £614 to arrive; if you manage to uncover any reasons for any of the three failures to pay (until I had to repeatedly intervene) I would also be most appreciative as previous requests have not received any answers. I do understand VSO’s stated reasons for failing to pay the remainder of my other, 2011, fee, although I believe that a substantive, open-minded discussion of the work and contract would show them to be fallacious, and save time, money, reputation and stress for all parties.

I look forward to VSO’s assessment of the situation. As I have previously mentioned, I find it baffling that this matter has ended up in court at all; there obviously exist many better uses of VSO’s resources and time, and of my own. I remain entirely constant in my ability and willingness to discuss all and any matter of this case outside of court or at court. I am happy to reach an amicable resolution to these proceedings and my trainer status; please let me know if you are willing to make any offers upon which I shall take advice. If we are able to reach a settlement then attendance of witnesses at court and additional costs can be avoided.


 


 


 


I looke forward to hearing from you; my number is XXXXX if that is easier for you.


 


Yours sincerely


 


 


 




David Hampson

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Expert:  UK-Justice replied 249 days and 21 hours ago.

That is quite a long post, can you summarise?

Customer replied 249 days and 21 hours ago.

hello UK justice.. I want any suggested edits to the top two emails please

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Expert:  UK-Justice replied 249 days and 21 hours ago.

No the emails are fine.

Although I would mention the rule which is CPR 26

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Expert:  UK-Justice replied 246 days and 10 hours ago.

I'm just following up with you to see how everything is going. Did my answer help?

UK-Justice

 
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