You represent a client who sustained serious injuries in a motor vehicle collision that he was involved in. He was the driver of a motor vehicle that collided with another motor vehicle. By making use of your own created facts/information, draft a section 19(f)(i) compulsory affidavit on behalf of your client that will form part of his third party claim that will eventually be submitted with the RAF. [10]
IN THE ROAD ACCIDENT FUND
In the matter between:
[Client's Name],
Plaintiff,
and
Road Accident Fund,
Defendant.
COMPELSORY AFFIDAVIT
I, [Client's Name], do hereby make an oath and state as follows:
1. I am an adult male residing at [Client's Address] and I am the Plaintiff in the above matter.
2. I have personal knowledge of the facts and circumstances relating to the motor vehicle collision that occurred on [Date] at approximately [Time] in [Location], which resulted in the serious injuries sustained by me.
3. I was the driver of a motor vehicle, a [Client's Vehicle Make and Model], bearing registration number [Client's Vehicle Registration Number], at the time of the collision.
4. I will refer to the driver of the other motor vehicle as the Defendant for the purpose of this affidavit.
5. On the aforementioned date and time, while I was driving in a lawful and proper manner, the Defendant, who was driving a [Defendant's Vehicle Make and Model] with registration number [Defendant's Vehicle Registration Number], negligently collided with my vehicle.
6. The collision occurred as a result of the Defendant's failure to maintain a proper lookout, exercise reasonable care, and adhere to traffic laws and regulations.
7. The impact of the collision caused severe damage to my vehicle and resulted in the following injuries sustained by me:
a) Fractured left leg
b) Multiple rib fractures
c) Head injury resulting in concussion
d) Whiplash injury to the neck and upper back
e) Soft tissue injuries to various other parts of the body
8. As a result of these injuries, I have suffered significant pain and suffering, emotional distress, and physical disability. I have been unable to return to work since the collision, resulting in lost earnings and financial hardship.
9. I have received medical treatment and continue to require ongoing medical care, rehabilitation, and therapy to recover from my injuries. The associated medical expenses, including consultations, surgeries, medications, and therapy sessions, have incurred significant costs.
10. I have not previously been involved in any motor vehicle collisions or suffered similar injuries.
11. I assert that all the information provided in this affidavit is true and correct to the best of my knowledge and belief, and I make this affidavit in support of my third party claim against the Road Accident Fund.
Sworn to and signed before me on this [Date] at [Place].
_____________________
[Client's Name]
Plaintiff
_____________________
Commissioner of Oaths