I/WE _______ (lawyer’s name) ________, claimant’s (or claimants’) legal practitioner, make oath and state as follows:

1. I/We have complied with the directions of the Pre-action Protocol as set out in Order 1 rule 1(4)(ii)(e) of the High Court Rules
2. I/We have made attempts to have this matter settled out of Court with the defendant and such attempts were unsuccessful. Such attempts include:
   
   1. Negotiation held on the _______ day of __________, _____________, which ended in a deadlock
   2. Attempts to reconvene another meeting to try to negotiate, which was never successful
   3. Mediation organised and headed by Prof Joash Amupitan SAN, which also ended in a deadlock
3. I/We have by a Written Memorandum to the defendant, set out the claimant’s claim and options of settlement

Dated at Lagos this ___________ day of _____________________, 2015