Preliminaries: I would like to call my first witness ___________.

The witness will be sworn in.

State the purpose of the offer of testimony: (usually nasa JA na to) I would like to offer the
testimony of ______ to prove…

Purpose: To prove the elements of the crime particularly that: (i) Accused obtained various loans
from private complainant which include the four (4) trust receipts and other loans secured by
Promissory Notes, the terms and conditions of which are provided for in trust receipt agreement;
(ii) Accused defaulted in the payment of their obligation as the same fell due and also failed to
return the goods covered by the trust receipts; (iii) despite demands Accused still failed to pay or
return the goods as he undertook to return under the trust receipts

Q: Good afternoon Mr. Witness. In relation to this case, do you recall having executed a
document entitled Judicial Affidavit?
A: Yes.

Q: If shown to you this document, will you be able to identify the same?
A: Yes.

Q: I am showing you a document entitled Judicial Affidavit. Kindly go over it.

Is this the same document that you mentioned earlier?
A: Yes.

Q: Now, Ms. Witness. Appearing on page 5 of this document is a name ___________, and on
top of the said name, there is a signature. Would you know whose signature it is?
A: That is my signature.

Q: Do you affirm and confirm the truthfulness and veracity of the contents of this Judicial
Affidavit?
A: Yes.

Q: Do you also affirm and confirm the truthfulness and veracity of the contents of the
attachments in this Judicial Affidavit starting (From Annex A – H) from Annex A – Promissory
Note dated June 27, 2016?
A: Yes.

Q: Annex B – Promissory Note dated July 1, 2016?

Q: Annex C – Promissory Note dated July 8, 2016?
Q: Annex D – Trust Receipts dated March 22, 2016
Q: Annex E – Trust Receipts dated July 11, 2016
Q Annex F - Trust Receipts dated July 21, 2016
Q Annex G- Trust Receipts dated August 22, 2016
Q: Annex H – Demand letter dated 15 May 2017

The signature of Accused referred to by witness as it appears in the Promissory Notes and Trust
Receipts is presented for comparison with originals and marking as Exhbits “A-1” and “A-2”,
“B-1” and “B-2”, “C-1” and “C-2”, “D-1” and “D-2”, “E-1” and “E-2”, “F-1” and “F-2”, and
G-1 and G-2 respectively

Q Your Honor, may we request that this Judicial Affidavit be marked as Exhibit L and the
signature on page 5 be marked as Exhibit L-1.

Q: Your Honor we also submit this Judicial Affidavit in lieu of the witness direct testimony.