Blake Gardner
Sep 03, 2013 7:47 AM1 of 2
AFFIDAVIT OF SPECIFIC NEGATIVE AVERMENT
The undersigned Affiant, Blah blah, hereinafter �Affiant�, does solemnly affirm, declare and state as follows:
A.Affiant is competent to state the matters set forth herein.
B.Affiant has knowledge of the facts stated herein.
C.All the facts herein are true, correct and complete, admissible as evidence and if called upon as a witness, Affiant will testify to
their veracity.
Plain Statement of Facts
1.There is no evidence that Blah blah has any remaining obligation to EKSPRES BANK A/S � Respondent, and the Affiant believes that no such evidence exists.
2.There is no evidence that EKSPRES BANK A/S � Respondent, have not received full satisfaction and payment of account � 123 by blah blah, and the Affiant believes that no such evidence exists.
3. There is no evidence that EKSPRES BANK A/S � Respondent, has returned the original negotiable instrument (g�ldsbrevet) or the equal value sum of Kr.15,846 back to the principal, Blah blah, and the Affiant believes that no such evidence exists.
4. There is as yet no evidence that EKSPRES BANK A/S � Respondent, have any intention of returning the original negotiable instrument (g�ldsbrevet) to Blah blah, and the Affiant believes that no such evidence exists.
5. There is no evidence that EKSPRES BANK A/S � Respondent, now has any right to withhold the collateral/property/surety of the original negotiable instrument (g�ldsbrevet), and the Affiant believes that no such evidence exists.
6. There is no evidence that EKSPRES BANK A/S � Respondent, is not damaging and/or causing Blah blah to suffer loss in withholding the collateral/property/surety of the original negotiable instrument (g�ldsbrevet) and/or the equal value sum of kr.15,846, and the Affiant believes that no such evidence exists.
7.There is no evidence that damages of Kr.2,000,000 paid by EKSPRES BANK A/S � Respondent, to Blah blah, would not be a reasonable compensation for fraud and all loss and inconvenience should the original negotiable instrument (g�ldsbrevet) not be promptly returned as requested or the value thereof, Kr.15,846, and the Affiant believes that no such evidence exists.
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Last Updated: Sep 03, 2013 7:47 AM
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