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.
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.
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.
Subject Access Request — CMS/DWP
All personal data held by CMS — calculations, correspondence, enforcement documents, call recordings — within 30 days. UK GDPR Article 15.
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.
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.
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.
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.
Challenge the Enforcement
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.
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.
Getting Parliament to Act
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.
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.
Escalate to Investigators
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.
SFO Referral Letter
Written referral to the Serious Fraud Office linking to the main investigation NCA referral.
JCIO Judicial Conduct Complaint
If your hearing was bulk-listed or a preliminary objection was refused — file at judicialconduct.judiciary.gov.uk.
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.
Challenge Registrations
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.
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.
Protecting Yourself at the Door
and at Work
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.
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.
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
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.
DWP Internal Complaint — Formal Route
Formal complaint to DWP — required before you can refer to the Parliamentary and Health Service Ombudsman (through your MP).
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