Summary
Summary Civil drafting
- Course
- Civil Procedure (LCVP4814)
- Institution
- University Of The Freestate (UFS)
Drafting of civil litigation founding affidavit
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IN THE NORTH GAUTENG HIGH COURT, PRETORIA(REPUBLIC OF SOUTH AFRICA)
CASE NUMBER: 1/2011
In the ex parte application of
JILL SAMANTHA KHUMALO (née Greene) APPLICANT
in re
JACK VUSI KHUMALO
(hereinafter referred to as “the patient”)
for the appointment of a curator ad litem
FOUNDING AFFIDAVIT
I, the undersigned,
JILL SAMANTHA KHUMALO
(ID 570324 0204 088),
hereby make oath and declare as follows:
1.
1.1 I am the Applicant in this matter. I am a major female pharmacist resident at 20 Queens
Crescent, Lynnwood, Pretoria.
1.2 The facts mentioned herein fall within my personal knowledge, unless specifically stated
as otherwise, and are to the best of my belief true and correct.
2.
I am married to the patient, Jack Vusi Khumalo, identity number 560719 0103 089, and
respectfully refer the Honourable Court to a true copy of our marriage certificate attached and
marked annexure “A”.
3.
AD BACKGROUND
3.1 The patient was involved in a motor vehicle accident on 5 January 2010 while he was a
passenger in a motor vehicle with registration number XYZ 456 GP, driven by myself.
The accident occurred at the corner of King and Queen Streets in Pretoria where the
aforementioned vehicle collided with another vehicle with registration number ABC 123
GP. I respectfully refer the Honourable Court to a true copy of the accident report
received from Brooklyn Police Station and marked annexure “B”.
3.2 As a result of the aforementioned accident, the patient suffered severe brain damage to
such an extent that he is completely dependent on me for his day-to-day needs. I am
currently solely responsible for taking care of him as he cannot walk, talk, bath or eat by
himself.
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