OCON1 (PD 51R) For further details of the courts www.gov.uk/find-court-tribunal © Crown copyright Page 1 of 8 Claim Form In the County Court Business Centre Online Civil Money Claims Claim number: 566MC444 Received on: 24 August 2024 at 5:42PM Issued on: 27 August 2024 1. Claimant’s details Name: MR GAVIN DADD Business name: Trading as G-TEC DIY & Building Address: 28, HILLFIELDS DEREHAM NR19 1UE Telephone: 07572374779 Email: gstyledesign2@gmail.com 2. Defendant’s details Name: MR Paul Carslisle Address: 5, CLICKERS ROAD NORWICH NR3 2DD Email: paulmichaelcarlisle@hotmail.com Claim number: 566MC444 OCON1 (PD 51R) For further details of the courts www.gov.uk/find-court-tribunal © Crown copyright Page 2 of 8 3. Claim Reason for claim: 3.1. This individual owes me money from work I have done for him/them [P. Carlisle and partner K. Price inclusive]. He was invoiced on the 1st July 2024. And still to this date, this bill remains unpaid and is still owing.? He claims that he does not have to pay be cause [quote] ‘I (me) refused to finish the work’? And also that ‘I walked off site’ (sic). Both of these allegations Are completely false, and untrue. It was actually him and furthermore his partner [Kate price] that asked me to specifically Leave the worksite, hence I did? I also have full proof and evidence of this which I will submit also, but I will do so separately and in the near future/ later date by means possible?. He [Carlisle] and his false claims, have cost me further 3 days of work to contest these matters from him and to seek legal advice/find a solicitor for myself. I have been affected with severe stress, upset and inconvenience by this whole matter [Am now under medical & doctors treatment for?]. He has also in this process in the very same week [Early July 2024] has also cost me two more additional separate jobs. - Being work that I had already booked in with customers, but that I had to cancel – Due to his actions [& my responses & admin work needed] thus rendering me unable to complete the work booked & promised for these people during/ on the said week & period that I mention & thus lost customers & income. Hence I claim for these losses also. 3.2. He has Contested my work - But overall has made an extremely spurious money claim against myself [ref 554 MC471] -Involving claims which consist of untruths and of which are incorrect. I have full and further proof to substantiate this also. Over 2 months have passed now and he STILL will not, and shows no sign of paying the outstanding bill amount. I must add I have now given him Four different & separate offers of resolution! [From July 1st onwards. Even before having to make this Claim here] - All of which have been put in writing to him - but All have been REFUSED & Declined by them. Additionally has negated to even reply to these offers.? [But then claims the oposite! then 'changes' stating that he has attempted resolution]. He has done none of the such most obviously. He has been Extremely devious & underhand in all these dealings (my offers, & honest intentions) plus other matters also thus far. Additionally I must mention, that I have also experienced & endured severe harassment from this individual. - receiving 40emails now [PLUS several defamatory online attacks and 'Public' reviews deliberately posted by this individual on my business], all of them false also. Additionally I have received multiple letters by post and also 38 texts [which I Claim number: 566MC444 OCON1 (PD 51R) For further details of the courts www.gov.uk/find-court-tribunal © Crown copyright Page 3 of 8 had to block him on phone messages, upon police advice also, as he would not desist]. Further, I have had to call the Police on more than Two occasions now and reported these matters of extreme harassment that I describe.!. I have further evidence to add to this, and to prove & substantiate my claim, but I will provide these separately and in the near future, as appears no means to do such [digitally/ online] at this stage. I wish nothing more than to resolve this, and just to simply have my bill & invoice paid, which I worked extremely hard for (as I always do), & to settle this matter. But he has just obstructed & obfuscated Any resolutions & offers made by myself also?. And has then just 'Flooded' my inboxes with emails etc [80% of which are just completely unnnecessary] - attempting to cause distress/ alarm and/ or upset as I have mentioned. Thannkyou Timeline of what happened: 15 May 2024 Visited to do initial survey and quote Estimate. I Quoted for four different separate jobs at the same property (Visit Lasted approximately 45 mins). He acted 'very distant' & pre occupied. 22 May 2024 After very ‘strange and confusing’ text message ‘thread’ & exchange [on 22nd May]. I had sent estimates several days before. But he seemed to not understand these, & also could not find his way around on his own computer to find the emails I had sent days previously. [This all came across as / appeared extremely unusual & 'Odd'. He questioned & (blamed) me at first - Then reneged realising 'I was in the right' as I had already said.? 12 June 2024 After much texting and [voice clip] messages.. [Carlilse became a very difficult customer - to arrange, or deal things with?]. I had literally dismissed any prospect or chance of working for him, as had heard nothing for almost a month. [Unusual in my line of work, with any genuine customers]. - But he then contacts 'out of the blue' [demanding a start the very next day? Which was impossible obviously]?. We eventually agreed a start date of Wednesday 19th June 2024. Claim number: 566MC444 OCON1 (PD 51R) For further details of the courts www.gov.uk/find-court-tribunal © Crown copyright Page 4 of 8 19th June 2024 I arrived on the first day of work and work commenced. - Carlisle also agrees to the extra work being done, and prices discussed [He has since denied in writing also]. Additionally the fact that concreting would need 24 hours to cure.? I submit evidence of this. 25th June 2024 Having been unwell and urged to rest under doctor's orders. - I Then Attended a second day- To continue where had left off.- Full days work done & completed. This was when at 'the end of the day' as I was leaving.. They unexpectedly 'commandered me' & offered this extra interim payment. (£95). I was surprised / taken aback, but accepted such, stating this amount will pay for 'the additional & unforeseen work' encountered extra to, & additional to.. the main first agreed estimate amount. 27th June 2024 Returned for final day, to ideally complete the work & gate [which WOULD have happened & been completed], if it were not due to a ‘very strange, hostile & 'Different attitude' (& personality 'switch' so to speak) from Carlisle?. - Due to his rude & obstructive Behaviour [I would suggest quite possibly Deliberate..]. Events and actions/ rudeness from them [him in particular] occurred. After he physically obstructed/ assaulted me.. and with him also Shouting several verbal abuse & threats.. I was about to leave But I was then asked to continue with the job [quote] ‘If I could please’ By his partner K. Price?. [I agreed after a mutual discussion with partner [K.P.]. Although then, Again.. Shortly after this.. [Carlsiles] attitude & behaviour became untenable, & after him shouting further accusations & abuse at myself from an upstairs window - I was asked to leave [after a mutual discussion with partner [K.P. again]. Hence results in myself ‘leaving site and the job’ at approximately 5:30-5:40 PM. With the smaller & final ‘hanging the gate’ part of the job, still needing completion / remaining unfinished. This was obviously as I say, was at the customer's request and insistence. Thus hence was rendered myself Totally unable to finish off the work I had Claim number: 566MC444 OCON1 (PD 51R) For further details of the courts www.gov.uk/find-court-tribunal © Crown copyright Page 5 of 8 diligently been doing that day, [& as had, all throughout]. Evidence: Statements of account I supply the copy of the first bill and invoice issued - On 1st July 2024 [Although admittedly there is ‘a typo’ on the date on this invoice]. This still remains unpaid and is owing.? They immediately refused to pay this. And it still stays owing to this day with interest accruing Letters, emails and other correspondence I then supply a further SECOND reduced bill that was an intention, and intended for resolution for all parties to settle upon? This was again immediately rejected by them and ignored.! I also supply, then a further THIRD reduced invoice, & offer of resolution? [Myself reducing the bill further yet again... in order to settle this?. Thinking that they may take that as an offer of a final settlement of interest and resolution for all parties?. Of course this was rejected again & dismissed.? This was in fact in reality - Even the same amount that they had offered me as an initial resolution? plus the amount of ‘overflow extra cost’ of materials purchased? [£22.95] Which they still have in their possession, [and are not paid for?.. - and are still not paid for, not to this day. Letters, emails and other correspondence I supply a copy of my further final resolution.. - A FOURTH Offer for Myself to come back and fix the gate [i.e. finish the work]. This was again rejected most obviously/ ignored.! Receipts I supply copies of all the receipts for the total amounts of materials used on the job from the beginning to finish, that I worked on?. This obviously amounts to more than the £110 materials deposit payment initially made by them. [which obviously does not cover the full total amount of materials purchased Overall for, and used on.. this job] Photo evidence I attach photographic evidence of, the work I completed that had been done.? I also supply a short video showing how the job was left? and including the moment I left it on the final day?. This Claim number: 566MC444 OCON1 (PD 51R) For further details of the courts www.gov.uk/find-court-tribunal © Crown copyright Page 6 of 8 proves undoubtably that's also carlisle's claims that a door was thrown on the ground by myself or similar, are completely untrue[which he has put in writing incidentally]. I supply these pictures also, in order that if it becomes necessary I can ‘talk you through/ whoever’ - as to what was done and why, and to what stage I was at [up until leaving] with the actual work in hand on that day etc. Other I supply numerous voice clips of audio recordings that I managed to obtain.? This was sporadic throughout my attendance. But absolutely definitely proves that Carlisle has been dishonest & lied about many points & declarations in his claim [e.g. denials by him, regarding agreeing to extra work being done?]. But also very much more importantly and I would suggest 100% pivotal to the whole case.. - These recordings further dismiss his false & untrue claims and lies that [A]- I ‘walked off the job’ Which he states.? And ? And [B] - That ‘I refused to complete the work’.? Both of these claims He has put in writing?. But these recordings taken at the time, prove that these are all unequivocally & totally lies.. and are baseless accusations? and are false claims also.!. As I will, and herewith prove. Thank you. If I might add also finally that the fact of this whole case revolves around the dishonest and spurious claims that Carlisle makes that ‘I walked off the job’, and I refuse to finish etc.? As you can & will see, he completely lies in this - you will see [hear] such when I present my evidence. These are just two of many other instances of lies & dishonest claims he makes Amongst others.. May I also please finally advise you that I am not the first [He has made claims against.!] - But this is not the first time that he has made legal battles against genuine and honest tradesmen that have worked for him, as I understand it.? He admitted to me in person, that he had been ‘locked in a legal dispute for a year with the last gardener that he hired’? [sic] ! It seems very much that history and matters repeat themselves? And in very strange circumstances also. With this Claim number: 566MC444 OCON1 (PD 51R) For further details of the courts www.gov.uk/find-court-tribunal © Crown copyright Page 7 of 8 and all of the above I present my claim/ defence/ counterclaim. 4. Claim amount details Claim amount items: Payment of Outstanding & Still Unpaid Invoice for work completed June 2024 [Includes TOTAL Value of job work done MINUS amounts already paid] £185 Loss of Earnings/ Booked work Lost [Provable] -due to having NO option but to deal with this (& Carlisle) £450 Loss of 1 x Full Days pay @ £200 p/day [Business time] Again.. to deal with Carlisles Extensive deluge of emails [& including calls & written responses And such to my solicitor also] - Also writing to police regarding [P. Carsliles 'Irrelevant continual emails & continual Harrassment towards myself] £200 Severe stress cause by all this matter. - As for myself, I have been diagnosed & additionally recovering from.. severe trauma & stress disorder, over the past 18 mnths £200 Interest rate claimed: 1.3% Explanation: As per Gov.uk Business legislation guidelines - B.O.E Baserate + 8% Claim number: 566MC444 OCON1 (PD 51R) For further details of the courts www.gov.uk/find-court-tribunal © Crown copyright Page 8 of 8 Date interest is claimed from: 1 July 2024 Explanation: This was the date of the first final invoice, after completion of the work [i.e. Me finishing- &/ or leaving site] - This original invoice is dated such [Although a 'typo error' on the date admittedly]. This was also the first day going forward that they officially refused to pay the said owing bill and invoice amount. Interest end date: Interest will accrue at the daily rate of £0.04 up to the date of judgment 5. Total amount Claim amount: £1,035 Total interest claimed to the date of submission: £2.10 Claim fee: £80 Total: £1,117.10 6. Statement of truth I believe that the facts stated in this claim form are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth. MR GAVIN DADD 27 August 2024 If you don’t respond before , you could get a County Court 4pm, 16 September 2024 Judgment (CCJ) made against you.