The ANSWERS (second part of the pleadings) are followed by AFFIRMATIVE DEFENCES and are really part b) of the ANSWERS demanding a little more application than the ANSWERS alone. Wikipedia has a good definition of AFFIRMATIVE DEFENSES so it is below. An affirmative defense to a civil lawsuit or criminal charge is a fact or set of facts other than those alleged by the plaintiff or prosecutor which, if proven by the defendant, defeats or mitigates the legal consequences of the defendant's otherwise unlawful conduct. Wikipedia

OK I've dealt with the COMPLAINTS part of the PLEADINGS so what comes next if the Defendant's Motion to Dismiss has been dismissed?
The next part of the PLEADINGS are the ANSWERS and this is really simple because at the Plaintiff's numbered paragraphs u simple write: Admitted
Denied or
Do not have sufficient knowledge to answer.
Councils, I have found, do not know this but seek to answer any complaint with long, winding and confusing sentences which have no bearing on the case. I would make a Motion for a More Definite Statement reminding

Pleadings revisited:
The first part of the pleadings is the complaint/petition which is also known as the summons.
Jurisdictional Allegations start the numbered sentences. They go a little like this:
1. This is a money claim for breach of contract for less than £xx 2. The claimant lives in the County of Gloucestershire 3. The Breach of Contract took place in Gloucestershire
4. The Defendant lives in the County of Gloucestershire5. The Court has jurisdiction
FACTUAL ALLEGATIONS
6.
7.
8. etc logical order

A pleading is a statement of case; the formal documents setting out the particulars of the claim, their legal basis, the defence (in 2 parts) and any reply to the defence. This corresponds with the summons, complaint+answer
It's covered under part 16 of the Civil Procedure Rule As you can see the Pleadings cover a number of documents from both sides. They must be written carefully because once the Pleadings are closed u cannot add any more information. If you don't follow the Civil Procedure Rules, the opposition could make a Motion to Dismiss

yesterday we looked at the Motions used in response to a Particular of Claim to try and keep the case out of court.
These were Motion to Dismiss
Motion for More Definite Statement (or clarification)
Motion to Strike Out.
A Particular of claim is the numbered complaint laying t out in a logical fashion the sequence of events that leads to the event that is being complained of. It can be fairly long or very short as you will find out on the council tax summons. Here' a link to a long one as an example taken off the CAB website citizensadvice.org.uk/Documents/Advi…

Motions to dismiss a hearing can be made on:
1) lack of subject matter jurisdiction ie is the ability of the court to exercise power over a particular type of case. (criminal, civil, family, probate etc)
2)Lack of personal jurisdiction; when u submit a complaint to the ct u are giving the court jurisdiction over yourself but what of the Defendant? Does the court have jurisdiction over them? Normally the court hears cases where the event complained of occurs or is where the Defendant resides. The rules governing this can be found in the Civil

@RAC_Care
The latest: after failing to diagnose properly the intermittent starting problems resulting us in having a new starter motor in which has not resolved the problem, the Customer Care team has put our request into an week process. They have ignored our reasonable request for a courtesy car. A car is necessary due issues of which they are aware of and in the light that we live too far away to access shops etc. We have tried 3 telephone numbers in an attempt to speak to someone at RAC but been passed onto another number which cuts out when

Immunology made very simple
1) mRNA is made when the double helix of the DNA unwinds revealing the part that carries the particular instructions for a specific protein.
one of its strands is used as a template for the synthesis of mRNA.
mRNA carries instructions it has obtained 2 from the bit of the DNA that unrolled to the factory to be made up. The factory is called a ribosome.
These instructions to make up a protein like a spike protein or enzyme may be a) translated immediately b) stored for later c) degraded
)with an mRNA jab there is no template

Zinc prevents spike protein from entering cells. Theoretically, those who have had mrna jab would protect themselves from spike protein damaging their cells by having adequate amounts of zinc in their diet. Plant eaters would not fare well in this respect neither wd elderly who are generally deficient in zinc and pple with malabsorption problems, those who are malnourished and others (still working on this). We have a solvable dilemma in that thiamine inhibits zinc, yet most ppl are deficient in both. I would say that atm zinc should be taken every

It is not necessary to take vit D and K at exactly the same time or any other recommended associated vits and minerals because the half life has not been considered in this scenario. For example vit D and K have 1/2 lives of around 24 hours. Therefore, if you take vitamin D at 6pm and vit K the following day at 10am they will still both be in your system. Further, both are stored in the fat cells in the body and can be withdrawn whenever needed. Vitamin C has a half life of approx 20 days so doesn't have to be taken exactly at same time as iron which

For all those who are made to feel ashamed because they are not engaged in energetic exercise/running here's the downside
Frequent strenuous exercise increases the chance of developing MND in genetically at risk individuals. Frequent strenuous exercise increases the risk of developing motor neurone disease (MND) in certain people, new research from the University of Sheffield has found.
I was involved with a local branch of the MND society for a while raising funds through book sales/garden events for them so I've known about this connection for

The file which the local authority should have sent down to the court in order (they say) for a summons to be served for non-payment of Council Tax is missing. This is likely because it was never sent in the first place because it is not an offence and neither magistrates nor civil court have jurisdiction in this matter.
Just for good measure I have also sent a Subject Access Request to the court requesting any info they hold on me. They won't have it!. They have already tried to get out sending it to me so I placed a complaint in to the Information

This Saturday my husband was called by an automated bot on his mobile. He has already informed Santander not to use his mobile phone. You have our landline and eventually a bot called us on that. We did attempt twice to ring the fraud team. We waited 2 separate

If you believe that you have only been living in an 'Alice in Wonderland' world since March 2020 then you might now begin to realise that most of what is going on around you to chop, shape, measure, medicate and educate you, (not a definitive list by any means) for most of your life is really an invention of other people's imagination who hold power in society and can use many means - perceived authority and'experts', dubious marketing to continue the hold that they have. There are good, genuine ppl in the world - to balance this statement- but you

When I am writing my books, I like to add details of small charities - responding to needs in the community - at the the back of the book. I never take anything for advice but if ppl wish to support the charities named in the book then I'm fine with that. I don't follow it up, just trust ppl to do that if they want. For 3 years the excellent work of the Exodus Project in Barnsley has been included in my books. The book on Hypertension included a cafe in the wilds responding to those who love nature. I would now like to add another community

It is really important that you gain as much knowledge about viruses as possible. Once you do, you will not be fearful of them again. Nor will you be conned They have certain characteristics which belong to their 'family' of viruses. Some change shape giving variants but nothing to worry about most of the time. Others remain stable and you will know which ones these are because there is generally a once in a lifetime jab - like smallpox, chicken pox, measles, rubella, generally aren't repeated after early childhood and u will have lifelong antibodies

Magnesium has analgesic properties
The benefits of magnesium in relieving pain and inflammation are becoming known. Studies have found that at the cellular level, magnesium reduces inflammation. It was found that when an inflammatory condition occurs then a magnesium deficiency is created. Increasing magnesium intake decreases inflammation.
Magnesium is actively required for the synthesis of approx. 700 enzymes any of which, if compromised through lack of magnesium have a detrimental impact on health.
There are a number of ways in which magnesium

Why do opioids work on pain?

The brain has a natural brake on pain. Once a pain stimulus hits the brain, the brain leaps into action and sends a signal back to the spinal cord to reduce the pain signal.

Two important molecules in this process are serotonin and encephalin. Serotonin is a chemical which nerve cells produce which allows messages to be passed between nerve cells. It is mostly found in the digestive system but it can be found in blood platelets and serum, too.

The messages it passes along are related to mood, sexual desire, memory

Fast and Slow Pain
A pain stimulus is transmitted through peripheral nerves to the spinal cord and from there to the brain. It can happen either through a fast nerve fibre or a slow one.
A fast pain is a sharp pain but after a few seconds this becomes a duller pain – like a burning pain. This can continue for days or weeks. Sometimes it can last much longer when it is classified as chronic pain.
Fast pain is transmitted by thick nerve fibres. They are called A-delta fibres. As they allow the pain stimulus to be transferred very quickly, it means

Pain can be initially divided into two categories. There is acute pain which starts suddenly and is short term. Chronic pain is often defined as any pain which lasts for more than twelve weeks. It may stem from acute pain which is a normal sensation that alerts us to illness or injury but the sensation of discomfort in chronic pain is entirely different. It is often accompanied by decreased appetite, mood changes, fatigue and, sleep disturbance among others. It may require an entirely different treatment approach than that of acute pain.

PPI's and antacids. Anything that reduces stomach acidity puts you at risk of being unable to digest food properly and benefit from the nutrients there in. You need a normal stomach acidity to separate cyanocobalamin(vitamin B12) from its protein source. Vitamin B12 is required for a healthy brain structure. People going to consultants for MS like symptoms will find that tests for vitamin B12 deficiency is the norm.
Further, the stomach acid deals effectively with any pathogens. Lower the stomach acidity - make it more alkaline with PPI's and antacids