AFFIDAVIT IN SUPPORT OF MOTION EX-PARTE

IN THE HIGH COURT OF LAGOS STATE

IN THE LAGOS JUDICIAL DIVISION

HOLDEN AT LAGOS

SUIT NO: LAG/065/2015

MOTION NO:.................

BETWEEN

MRS TILO VERONICA CLAIMANT

AND

ENTREPRENEURIAL BANK PLC DEFENDANT/APPLICANT

AND

FIRST INSURANCE PLC PARTY SOUGHT TO BE JOINED

AFFIDAVIT IN SUPPORT OF MOTION EX-PARTE

I, UguChukwu, Adult, Male, Christian, Nigerian of No. 33 Kilomashe Street, Aguda, Lagos, Nigeria, do make oath and state as follows:

• That I am the Managing Director of ENTREPRENEURIAL BANK Plc., the Defendant/Applicant in this suit, and by virtue of my position, I am very conversant with the facts of this case.
• That I have the authority of my employers to depose to this affidavit.
• That I am aware that there is a pending suit against the Defendant/Applicant instituted by the Claimant.
• That we do not deny the claims of the Claimant in this case.
• That however, the contract between the Claimant and the Defendant for the supply of Five Hundred bags of foreign rice was insured with FIRST INSURANCE Plc., and we were guaranteed that if anything happens to the rice, FIRST INSURANCE will be held completely liable and would indemnify the Defendant/Applicant for actions brought by the Claimant in respect to damages done to the goods.
• That the insurance agreement between the Defendant/Applicant is herein attached and marked as "exhibit A".
• That this application to issue third party notice to join FIRST INSURAN