WRITTEN ADDRESS

IN THE HIGH COURT OF LAGOS STATE

IN THE IKEJA JUDICIAL DIVISION

HOLDEN AT IKEJA

SUIT NO: HIC/02/2015

MOTION NO________

BETWEEN

KROWN NIGERIA LTD………............……………………………………………CLAIMANT/APPLICANT AND

KAT NIGERIA LTD……………………………....……………………………… DEFENDANT/RESPONDENT

WRITTEN ADDRESS

Introduction

My Lord, before this honourable court is an application for a motion on notice dated………..day of………….......... 2015 and filed on………. day of………. 2015. My Lord, the motion is brought pursuant to Order 39 Rule 1 High Court Civil Procedure Rules of Lagos State 2012 and the inherent jurisdiction of the court. My Lord, the motion is praying this honourable court to grant an interlocutory injunction restraining the Defendant/Respondent from…………………

My Lord, this motion is supported by a 12-paragraph affidavit deposed to by one

Obi Eze. My Lord, we rely on all the paragraphs of the affidavit particularly paragraphs 3-11.

Summary of Facts

(State the Facts in brief)

Issues for Determination

Legal Argument

My Lord, it is an established principle of Law that before an application of this nature can be granted, certain factors must be established which include: Legal Issue, balance of convenience, substantial issue to be tried.... These have been well established in the case of Obeya Memorial Hospital v. A.G. Federation & Anor. (1987) 7 SC (Pt.1) 52.

My Lord, we wish to submit that considering the fact deposed to in the affidavit already before this court, the Claimant/Applicant has a legal right and substantial issue to be tried.

Conclusion

We therefore urge the court to grant this application. We respectfully, submit.

Dated this…………………… day of……………………....…….. 2015.

Adebayo Okonkwo

CLAIMANT/APPLICANT'S SOLICITORS Yakubu & CO.,

No. 1 Maple Way, Victoria Island, Lagos.

FOR SERVICE ON:

Tomi Ade Esq.

DEFENDANT/RESPONDENT'S SOLICITOR

Plot A2 Ikoyl Lane, Lagos.

LIST OF AUTHORITIES CITED

1. Obeya Memorial Hospital v. A.G. Federation & Anor. (1987) 7 SC (Pt.1) 52.