IN THE MAGISTRATES COURT CASE No.

BYO CD 2534/23
FOR THE PROVINCE OF MATABELELAND
HELD AT BULAWAYO

In the matter between:

KHANONDO SAFARIS TOURS PLAINTIFF

And

DELMA LUPEPE DEFENDANT

DEFENDANT'S DISCOVERY AFFIDAVIT

I, DELMA LUPEPE the above named Defendant, do hereby make oath and say:

1. I am the Defendant in this matter, all the facts deposed herein are within my personal
knowledge and belief, true and correct.

2. I have in my possession or power the documents relating to the matters in question in this suit
set forth in the first part of the First Schedule hereto.

3. I have no documents in my possession or power the documents relating to the matters in

question in this suit set forth in the Second Schedule hereto.

4. 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 Legal
Practitioner/s or agent/s or in the possession, custody or power of any other person or persons
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 Schedule and Second Schedule hereto.

DATED AT BULAWAYO THIS 31st DAY OF JANUARY 2024.

…………………………………………
DELMA LUPEPE
Before me;

…………………………………………
COMMISSIONER OF OATHS

IN THE MAGISTRATES COURT CASE No. BYO CD 2534/23

FOR THE PROVINCE OF MATABELELAND
HELD AT BULAWAYO

In the matter between:

KHANONDO SAFARIS TOURS PLAINTIFF

And

DELMA LUPEPE DEFENDANT

FIRST SCHEDULE

PART I

1. Schedule of rental payments covering the period January 2023 till January 2024.
2. Copy receipt of rental payment in the sum of USD$15 000.00(Fifteen Thousand United
States Dollars Only).

SECOND SCHEDULE

NIL.