First of all I would like seek forgiveness in delaying answering the question (I refer my last post).
By the way, here are my answers:
- first of all, you need to file in your 'memorandum of appearence'- which I believe you have done so. By that I will not explain further the consequences should you fail to file the memorandum in time.
- second: you need to file in your 'statement of defense' within time, otherwise the plaintif may take 'judgment in default of defense' against you & you may not even aware it has been taken! because frankly, it's quite simple to be done.
- If you are late then quickly write letter to the plaintiff's solicitor (and cc to court) requesting them to grant you an extension of time, if they agree, good enough. But if they don't, you might need to do extra work by filing an application for an extension of time to file your statement of defense (remember you have to give good excuse on why you delay in filing it, and as usual the plaintiff may object).
- At the same time, I believe there is an application for specific injunction (or what normally called positive injunction-to compel you to do something or negative injunction to prevent you from doing something).
- the application for injunction order may be initiated from the main suit itself or by separate 'simmon-in-chamber' application. I presume there is a separate application since you did mention about affidavit in support presented by the plaintiff.
- so, what you need to do (simulteneously with item 2, or 3 above) is to quickly file in your 'affidavit-in-reply' opposing the injunction application.
- injunction works in 2 stages, first ex-parte injunction order which normally has been granted, an the order remains until inter-parte hearing of the injunction-which is coming due very soon (normally wothin 30 days validity period of the ex-parte injunction order unless the court grant an extension). second after hearing both parties arguement (by reading and hearing your affidavit in reply), they court may order an interim injunction until final disposal of the case should the main suit is all about injunction, only at the end of the suit the order of the injunction may become permanent or otherwise (depends very much on court judgment).
I don't have sample of statement of defense to share with/suit you simply because every statement of defense must be made specifically answering the statement of claims (and puting your 'counter-claims'), nontheless, you may find standard format in Rule of High Courts, 1980. get one for self for a very usefull guideline since you intend to fight your case personally. (please inform the court your intention to present your case personally so that they may not be so strict on proceedure).