WRITTEN ADDRESS IN SUPPORT OF APPLICATION FOR RENEWAL OF WRIT

IN THE HIGH COURT OF LAGOS STATE

IN THE LAGOS JUDICIAL DIVISION

HOLDEN AT LAGOS

SUIT NO:………………

MOTION NO__________

BETWEEN

OLA Balogun……………………………………………………………………… CLAIMANT/APPLICANT AND

JOHN JOSEPH………………………………………………………………DEFENDANT/RESPONDENT

WRITTEN ADDRESS IN SUPPORT OF APPLICATION FOR RENEWAL OF WRIT

Introduction

This application is brought pursuant to Order 6 Rule 6 (1) of the Rules of this Honourable Court. The Claimant/Applicant by the said application seeks an order of this Honourable Court for the renewal of the lifespan of the Writ of Summons in the suit. The application is supported by a 10 paragraph affidavit deposed to by the Claimant himself. We rely on all the paragraphs of the said affidavit especially paragraphs 3-9.

Issue for Determination

Whether the Claimant/Applicant is entitled to have her Writ of Summons and other originating processes renewed.

Legal Argument

With regard to the singular issue raised above, it is submitted on behalf of the Applicant that enough materials have been placed before this Honourable Court to persuade it to grant the relief sought by the applicant, to wit, an order renewing the lifespan of the Writ of Summons herein for a period of 3 months (or for two period of 3 months each).

We refer to paragraphs 4-8 of the affidavit in support. We therefore submit that the said paragraphs are sufficient proof that service of the Writ is impossible and that the lifespan of the said writ need o be extended. This Honourable Court his tie jurisdiction to grant the application pursuant to Order 6 Rule 6(1) of the Rules of this Honourable Court.

Conclusion

We therefore urge your lordship, most humbly to grant this application and extend the lifespan of the writ and other originating processes in the Suit for Three(3) months.

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

……………………………………

A.O Okonkwo, ESQ

Counsel to Claimant/Applicant.

71 Baruwa Street Festac Lagos State.

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