11. Paragraphs 5 - 6 of the Defendants’ AIS are denied and the Defendants are put to strict proof thereof. Upon perusal of the cause papers, I am advised by the Plaintiff’s solicitors and verily state that the Defendants’ Amendment Application does not only seek to include a new cause of action (i.e. counter claim), but also wholly changes the character of the suit by the addition of new parties. The Plaintiff will address/elaborate further in the following paragraphs of this Affidavit.
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