ABSTRACT

BETWEEN PATRICIA PARRY Plaintiff

and GWYNETH WILLIAMS Defendant

UPON MOTION this day made unto this Court by Counsel for the Plaintiff 2

AND UPON HEARING Counsel for the Defendant 3

AND UPON READING the Writ of Summons issued on the ___ day of _______ 199_ and the Plaintiff’s Affidavit filed the same day 4

AND the Plaintiff undertaking by her Counsel to abide by any Order this Court may make as to damages in case this Court shall hereafter be of the opinion that the Defendant shall have suffered only by reason of the Defendant’s undertaking hereinafter contained which the Plaintiff ought to pay 5

AND the Defendant undertaking by her Counsel that until after judgment of this action or further order she will not whether by herself her servants or agents or otherwise howsoever [set out the acts which the defendant undertakes not to do; eg ‘trespass on the Plaintiff ’s land at [address]’] 6

THIS COURT doth not think fit to make any Order on the said Motion save that the costs thereof be costs in the cause. 7

1 Heading. See further sample document (3) note 1 a-c, g at p 90. 2 This paragraph records the fact that the plaintiff ’s barrister

addressed the court. Note that the first two words are capitalised. 3 This paragraph records the fact that the defendant’s barrister

addressed the court. Note that the first three words are capitalised.