TAKE NOTICE that this Honourable Court will be moved on the …… day of ………………. 2012 at the Hour of 9 O’ clock in the forenoon or so soon thereafter as Counsel for the Claimant/Applicant will be heard praying this Court for:

1. AN ORDER OF INTERLOCUTORY INJUNCTION restraining the defendants, their agents, servant and any person acting on their behalf from holding itself out as the sole owner of the business of K &T PENDING THE DETERMINATION OF THE SUIT.
2. AN ORDER OF INTERLOCUTORY INJUNCTION restraining the defendant, agents, servants or any person acting on their behalf from selling or dissipating the assets of the business of K & T which the defendants have advertised for sale in the next five days PENDING THE DETERMINATION OF THE SUIT.
3. AND FOR SUCH FURTHER ORDERS as this Court may deem fit to make in the circumstances.

DATED THIS ….. DAY OF ……………………. 2012.

AFFIDAVIT IN SUPPORT OF MOTION ON NOTICE FOR INTERLOCUTORY INJUNCTION

I, EmekaWogu, Adult, Male, Christian and a Nigerian Citizen of No 15 Ikoyi road Lagos do hereby make oath and state as follows:

1. that I am the Managing Director of the Claimant and by virtue of which I am conversant with the facts of this case.
2. that I have the consent and authority of the Claimant/Applicant , my employer, to depose to this affidavit.
3. that I know as a fact that in the year 2006, both the Claimant and the defendant entered into an agreement to run a fast food business as a joint venture, a copy of the agreement is attached and marked as Exhibit A.
4. that it was a term of the agreement to share all the properties and profits equally.
5. that the defendant/Respondent has since been in charge of the business and has not been rendering accounts to the Claimant/Applicant.
6. the defendant has on several occasions boasted that the business of K & T solely belongs to it.
7. that the defendant/respondent has already advertised for the sale of K & T ‘s properties within the next five days, a copy of ThisdayNwespaper dated the 10 of June 2012 is attached hereto and marked as Exhibit B.
8. that damages will not be enough compensation to the Claimant/Applicant if the properties are sold.
9. it is more in the interest of justice to grant this application.
10. that I make this statement in good faith believing its contents to be true and correct in accordance with the Oaths Act.