1. The Plaintiff is a business woman and an exporter residing at No. 20 Bush Close Area 2 Garki Abuja.
2. The defendant is a public limited company with RC No. 1115 carrying on the business of banking and dully registered under the Companies and Allied Matters Act with its registered office address at No. 1 Area 1 Garki Abuja.
3. The plaintiff entered into a contract with the defendant on the 15 day of March 2000 for the supply of 500 tons of cashew nuts worth N10, 000, 000.00 only for onward exportation to Malaysia.
4. The term of the contract was that a down payment of N3, 000, 000.00 will be made before the exportation and the balance sum of N7, 000, 000.00 will be paid when the goods reaches Malaysia.
5. The plaintiff has received the down payment of N3, 000, 000.00 and has supplied the goods to its destination in Malaysia on the 30 of August 2001, the bill of exchange and Lading is hereby pleaded.
6. The plaintiff has written two letters of demands to the defendant dated the 10th day of January 2002 and 2 day of July 2002 respectively for the balance of N7, 000, 000.00 which the defendant has refused to pay, the letters of demand are pleaded.

The plaintiff therefore claims as follows:

1. The sum of N7, 000, 000.00 as the balance of the contract sum
2. The sum of N4, 000, 000 as general damages
3. Interest of 10 percent on the balance until the balance is satisfied.
4. The cost of prosecuting this suit.

DATED THIS……….. ………..DAY OF JUNE 2006.

REPLY AND DEFENCE TO COUNTER CLAIM

1. The Plaintiff joins issues with the defendant in respect to paragraphs 5, 7, 8, 9 and 10 of the defendant’s statement of defence and Counter-Claim.
2. The Plaintiff avers that the Defendant never at any time whatsoever, entered into any contract with Best Agrics Limited for the supply of 300 tons of cashew nuts but that the said 300 tons claimed to be supplied was part of the goods she supplied.



DEFENCE TO THE COUNTER-CLAIM

3. The Plaintiff admits paragraph 7 of the Defendant’s Counter-Claim.
4. The plaintiff denies paragraph 8 of the Counter-Claim and avers that the legal due date of the legal mortgage is on the 10 December 2000 and that when a Notice of Redemption is given to her as contained in clause 3 of the Deed of Mortgage, but the defendant has failed to deliver to her the notice of Redemption.
5. The plaintiff avers that an equity of redemption of the mortgage still exists in her favour.
6. The plaintiff whereof prays that the claim of the Defendant in the counter-claim be dismissed with cost as it lacks merit.

DATED THE …………… DAY OF …………. 2006

STATEMENT OF CLAIM TO RECOVER PROFESSIONAL FEES

1. The plaintiffs are the principal partners of Maji& Co, a firm of Legal Practitioners dully registered as a business name under the Companies and Allied Matters Act 2004 with its registered place of business at No. 15 Broad Street Wuse II Abuja.
2. The defendant is a business woman and supplier of agricultural products of No. 14 Garki II Abuja.
3. The plaintiffs were briefed by the Defendant on the 10 day of January 2012 to prosecute an action to recover the balance of N7, 000, 000.00 from her business partner Agricultural Bank Plc, the plaintiffs letter of instruction is hereby pleaded.
4. The defendant’s case was instituted in Court and dully completed on the 20 day of April 2012 as suit No FCT/CV/2012 MRS KAYUBA ADA V. AGRICULTURAL BANK, the judgment certificate is pleaded.
5. The defendant paid the sum of N200,000 as deposit to enable the plaintiffs carry out the instruction.
6. The plaintiffs aver that they never entered into any contingent fee arrangement with the defendant.
7. The plaintiffs have served on the defendant personally, a Bill of Charges dully signed and dated the 11 day of May 2012 to pay the balance of N410,000, the Bill ofCharges is hereby pleaded.
8. The defendant has refused to pay after 30 days of its service and a demand letter was sent to the defendant, the letter is hereby pleaded.
9. The Plaintiff hereby claims against the defendant as follows:
   
   1. The payment of the sum of N410, 000 balance by the defendant as contained in the Bill of Charges.
   2. Interest rate of 10 percent from the date of failure to pay after the 30 days grace until judgment is delivered and satisfied.