WRITTEN ADDRESS IN SUPPORT OF NOTICE OF INTENSION TO DEFENCE

IN THE HIGH COURT OF THE FEDERAL CAPITAL TERRITORY, ABUJA

IN THE ABUJA JUDICIAL DIVISION

HOLDEN AT ABUJA

SUIT NO:………………………..

MOTION NO___________

BETWEEN

KAYUBA OGE ……………………………………………………… PLAINTIFF/APPLICANT AND

QUEEN TOWERS LTD. ……………………………………. DEFENDANT/RESPONDENT

WRITTEN ADDRESS IN SUPPORT OF NOTICE OF INTENSION TO DEFENCE

INTRODUCTION

My Lord, before this honourable court is the notice of Defendant's intention to defend this action with counter affidavit disclosing a defence on the merit. The Notice is dated_____ day of________ 2015 and filed on___________ day of___________ 2015.

STATEMENT OF FACT

The suit was instituted by the Plaintiff/Applicant as a result of ………………………………..

ISSUES FOR DETERMINATION

Whether there is disclosure of defence on the merit to warrant the suit being heard under the general cause list.

LEGAL ARGUMENTS

The general position of law is that …………………………….

To this effect, the Defendant relies on the attached document marked Exhibit B...

My Lord, it is evidence from the above that the agreement was made to pay the sum of N10,000,000 (Ten Million Naira) to which the sum of N3,000,000 (Three Million Naira) for the commencement of the work

Flowing from the above arguments, it is the believe of the claimant/applicant that the defendants have no defence to the action as held in the case of Iron Products Ltd. v. SAC (1992) 4 NWLR (PT. 238) 734..

CONCLUSION

My Lord, in our submission, based on the detail argument canvassed in favour of the Defendant above and the facts contained in the pleadings coupled with unequivocal pieces of evidence, we urge the court to allow the Defendant to defend this action in the interest of fair hearing and justice as a disclosure of defence on the merit has been made.

LIST OF AUTHORITIES CITED

• Iron Products Ltd. v. SAC (1992) 4 NWLR (PT. 238) 734.
• ……………………………………………………………

Dated this _________day of May, 2015.

T.R ATEWOLOGUN, ESQ.

COUNSEL TO DEFENDANT