Template Library — 14 Templates — All Sections of the Dossiers

Letter, FOI &
Court Templates

These templates are based on the legal arguments documented across the four The CMS Files intelligence dossiers. Every template references the primary source evidence. Click any template to expand and copy the full text.

⚠ IMPORTANT — READ BEFORE USING ANY TEMPLATE

These templates are research guides only — they are not legal advice and will not always work. CMS Files is an independent public interest research investigation. Christina Little is a researcher and lay representative — not a solicitor, barrister, or regulated legal adviser. Nothing on this site creates a legal relationship or duty of care.

Every case is different. A template written for one situation may not fit yours. CMS may respond in unexpected ways. Courts have their own rules, time limits, and procedures. What works in one jurisdiction may not work in another.

The templates are based on primary source evidence — DWP's own FOI admissions, parliamentary records, NAO reports, court decisions, and government documents, all referenced within each template. The legal references are accurate to the best of our research, but they are not a substitute for qualified independent legal advice.

Before taking any action in court — filing an N244, appealing to the FTT, applying for judicial review — please seek independent legal advice.0800 144 8848 · Law Centres Network: lawcentres.org.uk

Replace ALL fields in [SQUARE BRACKETS] with your specific details before sending. Sending a template with brackets unfilled undermines your case.


Section 1 — Information & Data Requests

Get Your Documents First

You cannot challenge what you haven't seen. These templates secure your data, your court file, and CMS's own records before you take any further action.

T-01

Subject Access Request — CMS/DWP

All personal data held by CMS — calculations, correspondence, enforcement documents, call recordings — within 30 days. UK GDPR Article 15.

⚠ RESEARCH GUIDE ONLY — NOT LEGAL ADVICE — REPLACE ALL [BRACKETS] [YOUR FULL NAME] [YOUR ADDRESS] [DATE] Data Protection Officer Child Maintenance Service / DWP PO Box 200, Barnsley, S70 9AX SUBJECT ACCESS REQUEST — UK GDPR Article 15 / Data Protection Act 2018 s.45 I exercise my right of access to all personal data held about me. Please supply: 1. All maintenance calculations in my case — all inputs, methodology, and dates 2. All summonses, liability orders, enforcement documents in my name 3. All internal and external correspondence, emails, and notes relating to my case 4. All telephone call records and any recordings 5. All documents submitted to or received from HMCTS in my case 6. All records of DEOs, charging orders, driving licence/passport sanctions 7. My CMS case reference and SCIN numbers 8. All debt referrals to enforcement agents (Equita, Marston Holdings, Empira) 9. Any data shared with third parties including credit reference agencies and Registry Trust Ltd 10. All records of any hearing listings or bulk listing arrangements in my case My details: Name: [FULL NAME] · DOB: [DATE OF BIRTH] · NI: [NI NUMBER] · CMS ref: [IF KNOWN] I require a response within 30 days. Please confirm receipt. Yours faithfully, [YOUR NAME]
T-03

FOI Request — Summons Issuing Process

Confirm how, where, and by whom CMS summonses are generated. DWP's own FOI2026/50177 established the admission — this builds on it.

⚠ RESEARCH GUIDE ONLY — NOT LEGAL ADVICE — PERSONALISE ALL [BRACKETS] Submit via: whatdotheyknow.com or email: dwp.foi.requests@dwp.gov.uk Subject: FOI Request — CMS Summons Issuance Process — [YOUR NAME] Dear FOI Officer, Under the Freedom of Information Act 2000 I request: 1. Confirmation of whether CMEL7298 / CMEL7211 summonses are issued by a justice of the peace or by CMS operational staff 2. Confirmation of the address from which enforcement summonses are issued — specifically whether Plymouth or Wolverhampton CMS offices originate these 3. A copy of the current CMEL7298 template (any version) in use 4. The job title of the officer authorised to sign CMEL7298 summonses, and whether that officer is a justice of the peace 5. Confirmation of whether FOI2026/50177 (25 June 2026 — "this is the only document that constitutes the order") applies to all current CMEL7298 instruments [YOUR NAME AND CONTACT DETAILS]

Section 2 — Court Register & Liability Order Verification · KEY TEMPLATES

Ask the Court What It Actually Holds

These are among the most powerful tools available. A court that has no signed register entry, no sealed order, and no record of issuing a summons cannot lawfully have made a liability order — and will struggle to deny it in writing. These templates create the paper trail that proves it.

T-02A — PRIORITY · THE KEY DOCUMENT

Court Register Request — The Two Documents Only a Court Can Produce

The court only needs to do two things in a valid CMS enforcement case: (1) issue the summons (which must be issued by a justice of the peace under s.51 MCA 1980), and (2) make the liability order (which must be recorded in a signed, dated court register). The court register — signed, dated, with the Secretary of State named as informant — is the document that proves a genuine court process took place. If it does not exist, or if the informant is not the Secretary of State, the process was not a valid court process. This template asks the court to produce those two specific documents — or confirm they do not exist.

⚠ RESEARCH GUIDE ONLY — NOT LEGAL ADVICE — REPLACE ALL [BRACKETS] WHY THIS TEMPLATE MATTERS — THE LEGAL FRAMEWORK: The court has two and only two functions in a CMS liability order case: 1. ISSUE THE SUMMONS — under s.51 MCA 1980, a summons must be issued by a justice of the peace. Not by CMS. Not by a court admin officer. By a JP. DWP's own FOI team confirmed (FOI2026/50177, 25 June 2026) that the CMEL7298 document CMS serves is a CMS template — "the only document that constitutes the order." GLD confirmed in AC-2025-LON-001412 (Z2500859 para 8) that CMS served it, not the court. 2. MAKE THE LIABILITY ORDER — under s.33(3) CSA 1991, the court makes the order at a hearing. This must be recorded in the court register — signed and dated by the judicial officer. In valid proceedings, the INFORMANT (applicant) is the Secretary of State for Work and Pensions, acting through CMS. The register entry naming the Secretary of State as informant, with a date and judicial signature, is proof that a genuine court hearing with proper judicial involvement took place. If the court cannot produce (1) a JP-issued summons with court seal and court reference, or (2) a signed, dated court register entry naming the Secretary of State as informant — then no valid court process occurred. The liability order is void. This template asks the court to produce precisely these two documents — or confirm in writing that they do not exist. The response, either way, is evidence. [YOUR FULL NAME] [YOUR ADDRESS] [DATE] The Court Manager / Legal Services Manager [COURT NAME — e.g. Weston-super-Mare Magistrates' Court] [COURT ADDRESS] BY RECORDED DELIVERY FORMAL REQUEST — COURT REGISTER AND SUMMONS VERIFICATION CHILD MAINTENANCE PROCEEDINGS — [YOUR FULL NAME] CMS Reference: [YOUR CMS REF / SCIN IF KNOWN] Dear Sir/Madam, I write to request confirmation of two specific court documents which are required for valid Child Maintenance Service enforcement proceedings in my name. I make this request under the common law right of access to court records and under the Freedom of Information Act 2000. The court has two essential functions in a CMS liability order case: issuing a valid summons, and making a liability order recorded in the court register. I am writing to confirm whether this court holds evidence that either of those functions was carried out. ──────────────────────────────────────── REQUEST 1 — THE COURT REGISTER ENTRY ──────────────────────────────────────── Please confirm: (a) Does this court hold a signed and dated entry in the court register relating to Child Maintenance Service proceedings in my name? (b) If yes — please provide a certified copy of that register entry, confirming: • The date of the entry • The name and judicial designation of the officer who signed it (district judge or justice of the peace) • The name recorded as the INFORMANT in those proceedings In valid s.33(3) Child Support Act 1991 proceedings, the informant (applicant) is the Secretary of State for Work and Pensions, acting through the Child Maintenance Service. The court register should therefore name the Secretary of State as the informant. (c) If no signed and dated court register entry exists in my name in connection with CMS proceedings — please confirm this in writing. ──────────────────────────────────────── REQUEST 2 — THE SUMMONS AND LIABILITY ORDER ──────────────────────────────────────── Please confirm: (a) Was a summons issued by a justice of the peace of this court in proceedings in my name in connection with child maintenance enforcement? Under s.51 Magistrates' Courts Act 1980, a summons must be issued by a justice of the peace. If no JP of this court issued the summons — please confirm that in writing. (b) If yes — please provide a copy of the summons bearing: • The official court seal • The court case reference number • The name of the justice of the peace who issued it • The date and address of issue (c) Does this court hold a sealed liability order in my name? If yes — please provide a certified copy bearing the court seal, the court case reference, and the name of the judicial officer who made the order. If no sealed liability order exists on the court file — please confirm this in writing. ──────────────────────────────────────── WHY THIS MATTERS ──────────────────────────────────────── DWP's own Central FOI Team confirmed on 25 June 2026 (FOI2026/50177) that the CMEL7298 document served on me as a "liability order" is a CMS administrative template — described as "the only document that constitutes the order." On 27 June 2026, the Government Legal Defence confirmed in High Court proceedings AC-2025-LON-001412 (ref Z2500859 para 8) that CMS — not the court — served the summons. I am writing to this court to confirm what it actually holds on its own records. I require a written response to each question above within 14 days. Where a document does not exist, a written confirmation that it does not exist is itself the response I need. Yours faithfully, [YOUR NAME] [YOUR ADDRESS] [YOUR TELEPHONE / EMAIL]
T-02B

FOI to HMCTS — Bulk Listing Policy & CMS Administrative Arrangement

Request the agreement between HMCTS and CMS under which CMS "requests hearing space" — confirmed in FOI2026/03820 — and the policy governing bulk listings.

⚠ RESEARCH GUIDE ONLY — NOT LEGAL ADVICE Source basis: FOI2026/03820 (CMS "requests hearing space") · s.51 MCA 1980 · Article 6 ECHR Submit via: whatdotheyknow.com or hmcts.foi@justice.gov.uk Subject: FOI — CMS Hearing Arrangements and Court Register Policy Dear FOI Officer, Under FOIA 2000 I request: 1. The written agreement or service-level arrangement between HMCTS and CMS governing the provision of court hearing space for CMS enforcement proceedings 2. Any guidance issued to court staff on the listing of CMS enforcement hearings, including any "block listing" or simultaneous listing arrangements 3. The maximum number of CMS cases permitted to be listed in one session before a single judicial officer, and whether any minimum individual hearing time is specified 4. Confirmation of whether CMS generates summonses through the Libra court management system, or through a separate CMS system at CMS addresses 5. The policy on whether court registers record each case individually where multiple CMS applications are listed simultaneously 6. Confirmation of how many CMS enforcement cases were listed in a single session at [COURT NAME] on [DATE IF KNOWN] [YOUR NAME AND CONTACT DETAILS]

Section 3 — Formal Challenge Letters

Challenge the Enforcement

T-04

Void Instrument Challenge — to CMS

Formally dispute the summons and liability order. Cite DWP's own FOI admission. Demand suspension of enforcement. Send by recorded delivery and keep a copy.

⚠ RESEARCH GUIDE ONLY — NOT LEGAL ADVICE — THIS DOES NOT AUTOMATICALLY STOP ENFORCEMENT Sources: s.51 MCA 1980 · Hill [1983] 1 AC 328 · FOI2026/50177 · GLD Z2500859 para 8 [YOUR FULL NAME] [YOUR ADDRESS] [DATE] Child Maintenance Service — Enforcement [CMS ADDRESS] BY RECORDED DELIVERY FORMAL CHALLENGE — VOID ENFORCEMENT INSTRUMENT — CMS REF [YOUR REF] Dear Sir/Madam, I formally challenge the lawfulness of the enforcement instrument(s) issued in my case and demand immediate suspension of all enforcement pending your written response. GROUND 1: DWP'S OWN ADMISSION DWP Central FOI Team, FOI2026/50177, 25 June 2026: "This is the only document that constitutes the order" — confirming CMEL7298 is a CMS administrative template with no judicial origin. GROUND 2: JURISDICTIONAL NULLITY s.51 MCA 1980 requires a summons to be issued by a justice of the peace. On Hill [1983] 1 AC 328, a summons not so issued is void ab initio. The liability order founded on it is equally void. GROUND 3: GLD JUDICIAL ADMISSION In High Court proceedings AC-2025-LON-001412, GLD solicitor Ryan Jummun confirmed (Z2500859 para 8) that CMS — not the court — served the summons. [ADD IF APPLICABLE] GROUND 4: NO ORDER ON COURT FILE HMCTS has confirmed / I have written to [COURT] and received confirmation that no liability order in my name exists on the court file. MY DEMANDS — within 14 days: (a) Suspend all enforcement in my case (b) Produce a copy of the court-issued liability order — bearing the court seal, identified judicial officer, and court case reference (c) Confirm the address from which the summons in my case was issued (d) Confirm whether the informant in the court register is the Secretary of State If CMS cannot produce (b), confirm in writing that no court-issued liability order exists. Any enforcement continued after receipt of this letter is taken with full notice of this challenge. Yours faithfully, [YOUR NAME]
T-04B

Challenge to Calculation — s.33(4) Limitations Explained

A template challenging the calculation route — acknowledging the s.33(4) bar at enforcement stage and directing the challenge to mandatory reconsideration and FTT appeal.

⚠ RESEARCH GUIDE ONLY — NOT LEGAL ADVICE IMPORTANT: s.33(4) CSA 1991 means courts CANNOT check the calculation at enforcement stage. The calculation challenge must go through: (1) mandatory reconsideration by CMS; (2) FTT appeal. These are separate from the instrument validity challenge and must be pursued independently. [YOUR FULL NAME] [YOUR ADDRESS] [DATE] Child Maintenance Service [CMS ADDRESS] MANDATORY RECONSIDERATION REQUEST — CALCULATION DISPUTE CMS Reference: [YOUR REF] Dear Sir/Madam, I write to request mandatory reconsideration of the maintenance calculation in my case under regulation 10 of the Child Support (Maintenance Calculation Procedure) Regulations 2012. THE DISPUTE: [Describe specifically why the calculation is wrong — e.g. income figure used does not match your HMRC records, shared care nights are miscounted, variation has not been applied, etc.] SPECIFICALLY: • CMS has used an income figure of £[AMOUNT]. My actual income as assessed by HMRC for [YEAR] is £[AMOUNT]. [ATTACH P60 / HMRC RECORDS] • CMS has recorded [X] nights of shared care. The actual arrangement is [X] nights per [week/fortnight]. [ATTACH EVIDENCE OF CARE ARRANGEMENTS] • [OTHER SPECIFIC DISCREPANCY] I request reconsideration of the calculation on these specific grounds. I note that under s.33(4) CSA 1991, no court hearing an enforcement application can examine this calculation — making mandatory reconsideration and FTT appeal my only routes to correct an inaccurate assessment. If reconsideration does not resolve this dispute, I will appeal to the First-tier Tribunal. Please acknowledge this request within 14 days. Yours faithfully, [YOUR NAME]

Section 4 — Parliamentary & MP Letters

Getting Parliament to Act

T-05

MP Letter — Requesting Parliamentary Action

Write to your MP asking them to raise parliamentary questions, refer to the W&P Committee, and write to Baroness Sherlock on your behalf.

⚠ RESEARCH GUIDE ONLY — NOT LEGAL ADVICE — PERSONALISE ALL [BRACKETS] [YOUR FULL NAME] [YOUR ADDRESS] [DATE] [MP NAME], MP [CONSTITUENCY] House of Commons, London SW1A 0AA Dear [MP NAME], RE: CMS ENFORCEMENT — REQUEST FOR PARLIAMENTARY ACTION I am your constituent. I am writing about my personal situation with the Child Maintenance Service and about a matter of wider public concern. MY SITUATION: [Briefly describe what has happened — the summons received, enforcement taken, impact. 3–4 sentences.] THE WIDER ISSUE: DWP's own Central FOI Team confirmed on 25 June 2026 (FOI2026/50177) that the CMS "liability order" is "the only document that constitutes the order" — a CMS administrative template, not a court order. Under s.51 MCA 1980, a summons must be issued by a justice of the peace to be valid. CMS issues its own summonses from Plymouth and Wolverhampton. On 8 July 2026, approximately 300 liability orders were granted at Weston-super-Mare Magistrates' Court in a single sitting lasting just over one hour — with no individual judicial consideration and no examination of whether any debt is correct. This is replicated across England and Wales thousands of times each year. WHAT I ASK: 1. Write to Baroness Sherlock asking: was the summons in my case issued by a court or by CMS? 2. Submit this parliamentary question: "To ask the Minister of State for Work and Pensions, whether CMEL7298 constitutes a court order within the meaning of s.51 MCA 1980, and what steps she has taken following FOI2026/50177 (25 June 2026) confirming it is 'the only document that constitutes the order'" 3. Refer this matter to the Work and Pensions Select Committee (Debbie Abrahams MP) Full investigation: thecmsfiles.com Yours sincerely, [YOUR NAME]
T-05B

Letter to Baroness Sherlock Directly

Write directly to the Minister of State for DWP requiring her to explain the legal basis for enforcement in your specific case.

⚠ RESEARCH GUIDE ONLY — NOT LEGAL ADVICE Note: Ministerial correspondence is most effective when routed through your MP. You can write directly but response times may be longer and your MP's intervention carries more weight. [YOUR FULL NAME] [YOUR ADDRESS] [DATE] Baroness Sherlock OBE Minister of State, Department for Work and Pensions Caxton House, Tothill Street, London SW1H 9NA Dear Minister, RE: LEGAL BASIS FOR CMS ENFORCEMENT — CMS REFERENCE [YOUR REF] I write as a paying parent subject to CMS enforcement proceedings to request a ministerial explanation of the legal basis for enforcement in my case. YOUR DEPARTMENT'S OWN ADMISSION: On 25 June 2026, DWP's Central FOI Team confirmed (FOI2026/50177) that the document served on me as a liability order is "the only document that constitutes the order" — a CMS administrative template. No court-issued order has been produced or confirmed by HMCTS. THE LEGAL REQUIREMENT: Section 51 of the Magistrates' Courts Act 1980 requires that a summons be issued by a justice of the peace. The House of Lords confirmed in R v Manchester Stipendiary Magistrate ex parte Hill [1983] 1 AC 328 that a summons not so issued is void. MY QUESTIONS: 1. Was the summons in my case issued by a justice of the peace of [COURT NAME], or by a CMS officer? 2. Does HMCTS hold a signed court register entry and sealed liability order in my name? 3. Is the informant in my court proceedings listed as the Secretary of State? 4. On what legal basis is enforcement continuing during active High Court proceedings (AC-2025-LON-001412) challenging the lawfulness of this enforcement regime? I require a substantive response within 20 working days. Yours faithfully, [YOUR NAME]

Section 5 — Reporting to Police, SFO, JCIO and ICO

Escalate to Investigators

T-07

Action Fraud Report Guide

Step-by-step guide to reporting your summons as a potential false instrument. Online at actionfraud.police.uk. Links to NCA Referral Pending.

⚠ RESEARCH GUIDE ONLY — NOT LEGAL ADVICE Source basis: Forgery and Counterfeiting Act 1981 ss.1,3,9(1)(g) · National Crime Agency referral HOW TO REPORT TO ACTION FRAUD 1. Go to: actionfraud.police.uk → "Report a fraud" → "Other fraud" 2. Include this text in your description: "I have received what is presented as a court-issued summons and liability order from the Child Maintenance Service. DWP's own FOI response (FOI2026/50177, 25 June 2026) confirms the CMEL7298 document is a CMS administrative template — 'the only document that constitutes the order' — not a court order. Under s.51 Magistrates' Courts Act 1980, a valid summons must be issued by a justice of the peace. This was not. I believe this constitutes making and using a false instrument under the Forgery and Counterfeiting Act 1981 ss.1 and 3. CMS reference: [YOUR CMS REFERENCE] Template reference: CMEL7298 [if shown on your documents] I wish to link this report to National Crime Agency referral which covers this enforcement regime. Full investigation: thecmsfiles.com" 3. Note down your crime reference number 4. Submit your statement at thecmsfiles.com/portal.html — include your crime reference number
T-08

SFO Referral Letter

Written referral to the Serious Fraud Office linking to the main investigation NCA referral.

⚠ RESEARCH GUIDE ONLY — NOT LEGAL ADVICE — PERSONALISE ALL [BRACKETS] [YOUR NAME / "Anonymous — submitted online"] [DATE] Serious Fraud Office — reporting@sfo.gov.uk LINKED REFERRAL — NCA Referral Dear Sir/Madam, I write in support of National Crime Agency referral (The CMS Files investigation). MY CASE: [3–4 sentences — what happened, what documents, what enforcement, when] CMS Reference: [YOUR CMS REF] GROUNDS: 1. FALSE INSTRUMENT (FCA 1981 ss.1,3): DWP confirmed 25 June 2026 (FOI2026/50177) that CMEL7298 is a CMS administrative template — not a court order. Presenting it to extract money and authorise enforcement constitutes making and using a false instrument. 2. FRAUD BY FALSE REPRESENTATION (Fraud Act 2006 s.2): Using a document presented as a court order when DWP's own team has confirmed it is not. 3. PROCEEDS OF CRIME (POCA 2002 ss.327-329): The 20% surcharge (~£106m/yr nationally) extracted through enforcement on void instruments may constitute criminal property. 4. [IF APPLICABLE] FALSE IMPRISONMENT: I was committed to prison on [DATE] under a liability order that HMCTS has confirmed does not exist on the court file. Please link this to NCA Referral as supporting evidence. [YOUR NAME / Anonymous]
T-09

JCIO Judicial Conduct Complaint

If your hearing was bulk-listed or a preliminary objection was refused — file at judicialconduct.judiciary.gov.uk.

⚠ RESEARCH GUIDE ONLY — JCIO COMPLAINTS COVER CONDUCT, NOT DECISIONS Complaints about legal decisions (not judicial behaviour) are NOT accepted by JCIO. Submit at: judicialconduct.judiciary.gov.uk Court: [COURT NAME] · Date: [DATE] · Judicial officer: [NAME IF KNOWN] Nature: Procedural conduct — bulk listing / failure to hear preliminary jurisdictional objection Description: "On [DATE], [NUMBER] CMS liability order applications were listed simultaneously in a single session before [JUDICIAL OFFICER]. Each case was processed in approximately [TIME] per case. [IF APPLICABLE: When I/my representative raised a preliminary objection that the court lacked jurisdiction under s.51 MCA 1980 — because the summons was not issued by a justice of the peace — this objection was not heard / was dismissed without reasons / I was removed from the hearing.] This concerns judicial conduct — specifically: (1) failure to give individual judicial consideration to each case as required by Article 6 ECHR; (2) [if applicable] failure to hear a preliminary jurisdictional challenge before processing the substantive application." Note: Complaints must be made within 3 months of the event.
T-10

ICO Complaint — SAR Non-Response / Data Withholding

If CMS has not responded to your SAR within 30 days, or has unlawfully withheld data — complain to the ICO at ico.org.uk/make-a-complaint.

⚠ RESEARCH GUIDE ONLY — NOT LEGAL ADVICE Submit at: ico.org.uk/make-a-complaint → "Concerns about how an organisation has handled your information" Organisation: Child Maintenance Service / Department for Work and Pensions Include: "I submitted a Subject Access Request to the Child Maintenance Service on [DATE]. The 30-day response period expired on [DATE+30 DAYS]. [Select relevant:] [ ] I have received no response. [ ] The response was incomplete — specifically, CMS has not provided [DESCRIBE MISSING DATA, e.g. calculation inputs, call recordings, enforcement decisions]. [ ] CMS has withheld data without proper legal basis. I am requesting that the ICO require CMS to comply with its obligations under UK GDPR Article 15 and supply the outstanding data. My SAR reference (if provided by CMS): [IF KNOWN]" Note: You must make a complaint to the organisation first before the ICO will investigate. Keep a copy of your original SAR letter.

Section 6 — Credit Register & Property Challenges

Challenge Registrations

T-11

Registry Trust Ltd Challenge

Challenge a Registry Trust Ltd credit entry based on a void CMS liability order — affecting your credit file at Experian, Equifax, and TransUnion.

⚠ RESEARCH GUIDE ONLY — NOT LEGAL ADVICE — SEEK LEGAL ADVICE BEFORE CHALLENGING COURT-REGISTERED DEBTS [YOUR NAME] · [YOUR ADDRESS] · [DATE] Registry Trust Limited 153–157 Cleveland Street, London W1T 6QW rtl@registry-trust.org.uk FORMAL CHALLENGE — REGISTRATION BASED ON VOID INSTRUMENT Full name: [NAME] · DOB: [DOB] · RTL reference: [IF KNOWN] BASIS: DWP FOI2026/50177 (25 June 2026) confirmed the CMEL7298 "liability order" is "the only document that constitutes the order" — a CMS administrative template with no court seal, no court reference, and no judicial officer identified. An RTL registration requires a valid court order. This is not one. DEMANDS: 1. Suspend any consequences of this entry pending review 2. Remove the entry within 28 days 3. Notify all credit reference agencies I reserve all rights including judicial relief and regulatory referral to the FCA and ICO if this entry is maintained having been formally notified it may be void. Yours faithfully, [YOUR NAME]
T-12

Land Registry Objection — Charging Order Based on Void LO

Challenge a charging order restriction registered at Land Registry where the underlying liability order is a void CMS template. Uses Form ADV1 (objection) or write to Land Registry directly.

⚠ RESEARCH GUIDE ONLY — NOT LEGAL ADVICE — SEEK INDEPENDENT LEGAL ADVICE BEFORE CHALLENGING LAND REGISTRY ENTRIES — ERRORS CAN AFFECT YOUR TITLE Sources: Land Registration Act 2002 · Land Registration Rules 2003 r.91 · FOI2026/50177 [YOUR NAME] · [YOUR ADDRESS] · [DATE] HM Land Registry — Requisitions PO Box 74, Gloucester, GL14 9BB RE: FORMAL OBJECTION — RESTRICTION ENTRY — TITLE NUMBER [YOUR TITLE NUMBER] Property: [YOUR PROPERTY ADDRESS] Dear Sir/Madam, I write to formally object to a restriction registered against the above title on the grounds that the underlying liability order on which the charging order is based is not a valid court order. GROUNDS: The charging order registered against this title is derived from a CMS liability order in my name. DWP's own Central FOI Team confirmed on 25 June 2026 (FOI2026/50177) that the CMEL7298 "liability order" is "the only document that constitutes the order" — a CMS administrative template with no court seal, no court case reference, and no identified judicial officer. It is not a court order. A charging order cannot validly be based on a document that is not a court order. [ADD IF AVAILABLE: HMCTS has confirmed in writing that no liability order in my name exists on the court file at [COURT].] I request that Land Registry: 1. Note this objection on the register 2. Invite the beneficiary of the restriction to demonstrate the validity of the underlying liability order 3. Cancel the restriction if the beneficiary cannot produce a court-issued liability order with court seal and identified judicial officer Alternatively, I am prepared to apply to the First-tier Tribunal (Property Chamber) under Schedule 4 para 5 of the Land Registration Act 2002 for cancellation of the entry. Yours faithfully, [YOUR NAME]

Section 7 — Responding to Enforcement Agents & Employers

Protecting Yourself at the Door
and at Work

T-13

Enforcement Agent Notice — At Your Door

What to say and what to ask when Equita or Marston Holdings enforcement agents arrive at your home. Establishes your right to see their authority.

⚠ RESEARCH GUIDE ONLY — NOT LEGAL ADVICE — DO NOT PHYSICALLY OBSTRUCT ENFORCEMENT AGENTS — RECORD EVERYTHING IF POSSIBLE Sources: Tribunals Courts and Enforcement Act 2007 Schedule 12 · Christie v Leachinsky [1947] If enforcement agents (Equita, Marston Holdings) attend your home, say clearly: "I require you to produce: (1) Your authorisation document confirming you are acting under a valid writ or warrant (2) A copy of the liability order you are enforcing — specifically one bearing the court seal of [COURT NAME] and the name of the judicial officer who made it (3) Your Schedule 12 (Tribunals Courts and Enforcement Act 2007) compliance certificate DWP's own FOI team has confirmed that the CMEL7298 document served as a liability order is a CMS administrative template — not a court order (FOI2026/50177, 25 June 2026). I dispute that you have valid authority to act. I am not refusing access at this point, but I am formally notifying you of this dispute. Please note your name, badge number, and the documents you have produced." AFTER THEY LEAVE: • Write down immediately: their names, badge numbers, the documents they produced (or failed to produce), the time and date • Send a follow-up letter to Equita/Marston Holdings head office documenting the visit and your challenge • Submit a statement at thecmsfiles.com/portal.html
T-14

Employer Letter — DEO Dispute Notice

Write to your employer formally recording that the DEO is disputed — does not suspend the order but creates a paper trail and puts your employer on notice.

⚠ RESEARCH GUIDE ONLY — NOT LEGAL ADVICE — THIS DOES NOT SUSPEND THE DEO A DEO is not based on a liability order — it is a separate administrative power under s.31 CSA 1991. It is harder to challenge on void instrument grounds. The calculation challenge route (mandatory reconsideration/FTT) is usually more effective for DEO disputes. Source: s.31 CSA 1991 · CMS DEO guidance [YOUR FULL NAME] [YOUR ADDRESS] [DATE] [EMPLOYER PAYROLL / HR MANAGER] [EMPLOYER ADDRESS] FORMAL NOTICE — DISPUTED DEDUCTION FROM EARNINGS ORDER Employee: [YOUR NAME] · NI Number: [NI NUMBER] Dear Sir/Madam, I write to formally notify you that the Deduction from Earnings Order (DEO) received by you from the Child Maintenance Service in respect of my wages is disputed. THE DISPUTE: The maintenance calculation on which this DEO is based is subject to a formal mandatory reconsideration request / First-tier Tribunal appeal. [SPECIFY WHICH AND WHEN SUBMITTED.] The debt amount deducted does not reflect [my actual income / the correct shared care arrangements / other — specify]. I am not requesting that you cease deductions — you are legally obliged to comply with the DEO while it remains in force. However, I am formally recording that the underlying debt is disputed so that any future resolution may be applied retrospectively. Please retain this letter on my employment file. I will notify you of the outcome of the reconsideration/appeal. Yours faithfully, [YOUR NAME]

Section 8 — Court Applications · Seek Independent Legal Advice

Court Application Guides

These are guides to the court processes available — not instructions. Court applications have strict rules, time limits, and fees. Seek independent legal advice before filing anything in court.0800 144 8848

T-15

N244 Application — Set Aside Order (Guidance)

Guidance on using Form N244 to apply to set aside a county court order (charging order, enforcement order) based on a void underlying liability order.

⚠ RESEARCH GUIDE ONLY — SEEK LEGAL ADVICE BEFORE FILING — N244 HAS FEES — FEE REMISSION AVAILABLE ON LOW INCOME (HWF APPLICATION) Sources: CPR Part 23 · Form N244 · Hill [1983] · Tsfayo [2006] FORM N244 — APPLICATION NOTICE — OVERVIEW What it does: Asks a court to set aside, vary, or stay an existing order. When to use: To challenge a charging order, a final charging order, or an enforcement order where you believe the underlying liability order is void. Where to file: The court that made the order you are challenging. Fee: Currently £108 (subject to change). Fee remission available if on low income — apply using Form EX160 (Help with Fees / HWF application). See hmcts.gov.uk for current fees. What to include on the N244: • Section 3 (Order sought): "Set aside the charging order / enforcement order made on [DATE] on the grounds that the underlying liability order was made without jurisdiction, the summons having not been issued by a justice of the peace as required by s.51 Magistrates' Courts Act 1980 (R v Manchester Stipendiary Magistrate ex parte Hill [1983] 1 AC 328)" • Section 10 (Evidence): Attach: your court register request response; HMCTS confirmation no order on court file; DWP FOI2026/50177; your challenge letter to CMS and their response Key arguments: 1. Jurisdictional nullity — summons void (s.51 MCA 1980 / Hill [1983]) 2. Article 6 — bulk listing, no individual consideration (Tsfayo [2006]) 3. [If HMCTS confirmed no LO on file] — no valid underlying order Time limit: Normally 21 days from the order, but courts have discretion to extend where there is a good reason for delay. The systemic nature of the CMS instrument issue may be relevant to explaining delay. IMPORTANT: Get legal advice before filing if you can. A wrongly-completed N244 can be struck out and you may lose the fee.
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DWP Internal Complaint — Formal Route

Formal complaint to DWP — required before you can refer to the Parliamentary and Health Service Ombudsman (through your MP).

⚠ RESEARCH GUIDE ONLY — NOT LEGAL ADVICE You must complete DWP's complaints process before referring to the PHSO (Parliamentary and Health Service Ombudsman). The PHSO referral must go through your MP. [YOUR FULL NAME] [YOUR ADDRESS] [DATE] CMS Complaints — DWP Mail Handling Site A, Wolverhampton, WV98 1AF FORMAL COMPLAINT — CMS ENFORCEMENT — [YOUR CMS REF] Dear Sir/Madam, I make a formal complaint about the following CMS conduct: COMPLAINT 1 — VOID ENFORCEMENT INSTRUMENT CMS has used a CMEL7298 template document — confirmed by your own FOI team as an administrative template, not a court order (FOI2026/50177, 25 June 2026) — to [seize my wages / register a charge / threaten imprisonment / other]. This is maladministration. COMPLAINT 2 — [ADD FURTHER COMPLAINTS AS APPLICABLE] [e.g. incorrect calculation, failure to respond to SAR within 30 days, enforcement during disputed calculation, etc.] WHAT I REQUIRE: • Formal response within 15 working days (CMS complaint standard) • Written confirmation of the legal basis for using CMEL7298 as an enforcement instrument • Suspension of enforcement while the complaint is investigated • [Any specific remedy you are seeking] If I do not receive a satisfactory response, I will refer this matter to the Parliamentary and Health Service Ombudsman through my MP. Yours faithfully, [YOUR NAME]
All templates: research guides based on primary source evidence — not legal advice

Christina Little is a researcher and lay representative — not a solicitor, barrister, or regulated legal adviser. These templates document the evidence and the legal arguments as researched — but your case is unique and these guides will not always produce the result you need.

Free independent legal advice:0800 144 8848 · Law Centres Network lawcentres.org.uk · Advocate (Bar pro bono) weareadvocate.org.uk