DRAFT APPLICATIONS FOR DEFAULT JUDGEMENT

IN THE HIGH COURT OF LAGOS STATE

IN THE IKEJA JUDICIAL DIVISION

HOLDEN AT IKEJA

SUIT NO:…………………

MOTION NO__________

BETWEEN

DAYO AKOMOLAFE………………………………………………….. CLAIMANT/APPLICANT AND

BERKLEE LTD…………………………………………....……… DEFENDANT/RESPONDENT

MOTION ON NOTICE

BROUGHT PURSUANT TO ORDER 20 RULE OF THE HIGH COURT LAGOS STATE

(CIVIL PROCEDURE) RULES 2012 AND THE INHERENT JURISDICTION OF THIS HONOURABLE COURT

TAKE NOTICE that this Honorable Court may be moved on the____ of March, 2015

at the hour of 9 O'clock in the forenoon or so soon thereafter as counsel to the Claimant/Applicant may be heard praying this Honourable Court for the following orders:

• AN ORDER OF THIS HONOURABLE COURT ENTERING FINAL JUDGMENT IN FAVOUR OF THE APPLICANT AS PER HIS WRIT OF SUMMONS FOR FAILURE OF THE DEFENDANT TO FILE HIS STATEMENT OF DEFENCE.
• AND FOR SUCH ORDER OR FURTHER ORDERS as this Honourable Court may deem fit to make in the circumstance.

GROUNDS FOR THE APPLICATION

TAKE FURTHER NOTICE that the ground of this application is that the defendant having been served with all relevant originating processes in this suit has failed to enter appearance or file a statement of defence within the time stipulated by the rules of court.

Dated this 18th day of March, 2015.

……………………………………

Kuti Tunde.Esq

Counsel to Claimant/Applicant Whose address for service is: 90, Akerele Street I