WRITTEN ADDRESS IN SUPPORT OF APPLICATION FOR LEAVE TO ATTACH IMMOVABLE PROPERTY

IN THE HIGH COURT OF LAGOS STATE

IN THE LAGOS JUDICIAL DIVISION

HOLDEN AT LAGOS

MOTION NO:…………………

BETWEEN

KROWN NIGERIA LTD ....................................................

CLAIMANT/APPLICANT

AND

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

WRITTEN ADDRESS IN SUPPORT OF MOTION

Introduction

My Lord, this is an application in which the Judgement Creditor is seeking the Order of Leave of this Honourable Court to attach the immovable property of the judgment debtor.

Brief Statement of Facts

Issue for Determination

My Lord, the major issue sought out here is whether the applicant is entitled to an order of this Honourable Court to attach the immovable property of the judgement debtor.

Legal Argument

Conclusion

My Lord, we therefore urge the Court to grant the application. We move in terms of our motion papers.

Dated this……………………………..day of March, 2015.

F.C COLE ESQ

COUNSEL TO DEFENDANT/APPLICANT

21 Cole Street, Awoyaya Lekki, Lagos.

FOR SERVICE ON

A.O Whenayon. Esq

COUNSEL TO CLAIMANT

Whose Address to Service: Suite 45,Kings Route, VGC, Lagos. (b)Application for Garnishee Order

IN THE HIGH COURT OF FEDERAL CAPITAL TERRITORY

IN THE ABUJA JUDICIAL DIVISION

HOLDEN AT ABUJA

SUIT NO:…………………….

BETWEEN

Sunrise Kitchen LTD ………………………………………….. Judgement Creditor/Applicant

AND

• TDJ LTD………………………………………………………………….. Judgement Debtor
• ZEROX BANK PLC …………………………………………………….Garnishee/Respondent

MOTION ON EX-PARTE

BROUGHT PURSUANT TO ORDER……………. RULE ……………JUDGEMENT

ENFORCEMENT RULES AND UNDER THE INHERENT JURISDICTION OF THE HONOURABLE COURT.

TAKE NOTICE that this honourable court shall be moved on……………………. day of …………………….2015 at the hour of 9.00am or so soon thereafter as the Counsel for the Judgement Creditor/Applicant shall be heard for an application praying the court for: