* Brand & van der Bergh Attorneys, Desere Barnard, Millers Inc, Arno Crous, Graeme Johnstone, Hilary Johnstone, Frode Moe, Talitha Moe.
* 04 Jul: LJ Re H51/19: LJ v GHJ: Facts in / Not in Dispute Info
* Tygae: EoP Leg Sub: LJ v GHJ, LJ v FTM / EoP NWO SCO: EoP NTE GM: EoP NTE GMZA| EoP Axis MilNec Evac: Lotto: EoP v WiP Law, EoP v WiP Academia, EoP v WiP Media, EoP v WiP Charity, EoP v WiP Psych, EoP v WiP Religion, EoP v WiP Peacenik / EoP v WiP Neg.
From: Lara Johnson [mailto:firstname.lastname@example.org]
Sent: Saturday, July 04, 2020 12:01 PM
To: ‘Brand & van der Bergh Attorneys: Desere Barnard: Rachel Hannies’; ‘Millers Inc: Arno Crous’
Cc: ‘Graeme Johnstone’; ‘Hilary Johnstone’; ‘Frode Moe’; ‘Talitha Moe’
Subject: Re H51/19: LJ v GHJ: Req Facts in/Not in Dispute Info
TO: H51/19: Counsel: Arno Crous, Desere Barnard
CC: H51/19: LJ v GHJ & 3 Others Respondents.
Ms Barnard and Mr Crous:
Re H51/19: LJ v GHJ: Facts in/Not in Dispute Info.
To help reduce H51/19 – and/or if you or your clients stil insist on action proceedings EQ 02/20 – physical appearances in court to a minimum for any and all parties; by ascertaining via written response and reply affidavits; what facts are in dispute; and what facts are not in dispute.
Would your clients be willing to submit their Notice to Oppose affidavits clarifying:
[A] Any questions they have regarding Applicants affidavit statements;
[B] Facts Not in Dispute: Which of Applicants facts do they not dispute; so that we can all focus on facts in dispute.
[C] Facts in Dispute: Which of Applicants facts do they dispute. And if so to include their particular how, who, where, when and why subjective opposing facts information.
[D] Any additional information they request from Applicant, so that Applicant can provide such information if she has personal knowledge of it. If Applicant does not have access to the information, Applicant can request such information from any party who has access to such information, for such persons affidavit reply.
To reduce applicant and respondents physical appearances at the police station for the signing of affidavits before SAPS Commissioner of Oaths:
Applicant consents to respondents affidavits (a) to include the following closing paragraph: “I am willing to provide written affidavit answers to any written affidavit questions from any of the disputing parties. I confirm that I know and understand the contents of this affidavit. If so requested in writing, I am willing to sign it before a Commissioner of Oaths.”; (b) to be signed before their counsel as their Commissioner of Oaths substitute witness; and stamped by their Counsel law firm stamp.
EoP/OKC TRC Negotiations correspondence is published at EoP Leg Sub [eop-leg-sub.tygae.org.za]
EoP MILED Clerk [EoP Oath PDF]
16 Taaibos Ave, Heatherpark, George, 6529
Sent per electronic notice to:
Graeme and Hilary Johnstone:
Graeme Johnstone (email@example.com); Hilary Johnstone (firstname.lastname@example.org); Brand & van der Bergh Attorneys: Desere Barnard: Rachel Hannies (email@example.com);
Frode & Talitha Moe:
Frode Moe (firstname.lastname@example.org); Talitha Moe (email@example.com); Millers Inc: Arno Crous (firstname.lastname@example.org)