AN CHÚIRT CHUARDA
AFFIDAVIT OF DOCUMENTS
1. I have in my possession or power the documents relating to the matters in question in this suit set forth in the first and second parts of the First Schedule hereto.
2. I object to produce the said documents set forth in the Second Part of the said First Schedule hereto.
3. (Here state upon what grounds the objection is made, and verify the facts as far as may be necessary).
4. I have had, but have not now, in my possession or power the documents relating to the matters in question in this suit set forth in the Second Schedule hereto.
5. The last-mentioned documents were last in my possession or power (state when).
6. (Here state what has become of the last-mentioned documents, and in whose possession they now are).
7. According to the best of my knowledge, information and belief, I have not now, and never had in my possession, custody or power, or in the possession, custody or power of my solicitors or agents, solicitor or agent, or in the possession, custody or power of any other persons or person on my behalf, any deed, account, book of account, voucher, receipt, letter, memorandum, paper, or writing, or any copy of or extract from any such document, or any other document whatsoever, relating to the matters in question in this suit, or any of them, or wherein any entry has been made relative to such matters, or any of them, other than and except the documents set forth in the said First and Second Schedules hereto.
power of the Plaintiff (or Defendant)).