WRITTEN ADDRESS IN SUPPORT OF APPLICATION FOR STAY OF EXECUTION

IN THE HIGH COURT OF LAGOS STATE

IN THE LAGOS JUDICIAL DIVISION

HOLDEN AT LAGOS

SUIT NO: HC/LAG/63/15

BETWEEN;

KAT NIGERIA LTD……………………………………. APPELLANT/APPLICANT AND

KROWN NIGERIA LTD ………………………………....………….RESPONDENT

WRITTEN ADDRESS IN SUPPORT OF MOTION

Introduction

My Lord, this is an application in which the Judgement Creditor is seeking the Order of

Stay of Execution of judgement of this Honourable Court pending the determination of appeal already filed.

Brief Statement of Facts

My Lord, the 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 stay the execution of judgement having filed a Notice of Appeal.

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.