Discovery

I, the undersigned,

do hereby make oath and say that:

1. I am an adult [insert gender] and the Plaintiff in this matter. The facts deposed to herein, are within my personal knowledge and belief and are true and correct save where the context indicates otherwise.

The Plaintiff has in its possession or power the documents relating to the matters in question in this action as set forth in the first and second parts of the First Schedule hereto.

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