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    Math

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    kenethhailonga
    yeam

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    Math

    Uploaded by

    kenethhailonga
    6 views3 pages
    yeam

    Original Title

    math

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    yeam

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    6 views3 pages

    Math

    Uploaded by

    kenethhailonga
    yeam

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 3

    Page |1

    PARTICULARS OF CLAIM

    1. The Plaintiff is MARGARETH UAAPI KAUNAPAWA KAKUVA, an adult


    female Namibian person, having full legal capacity, residing at DR’s houses
    Oshakati State Hospital, Oshana Region, and employed as an Intern Medical
    Doctor, Oshakati, Oshana Region, Republic of Namibia.

    2. The Defendant is KAMBINDA DOMINGU, an adult male Namibian person,


    having full legal capacity, residing at Mariental, ǁKaras Region, and employed
    at Social Security Commission, Mariental, ǁKaras Region, Republic of
    Namibia, with mobile contact number 0812852221, and whose full and further
    particulars are unknown to the plaintiff.

    3. The parties are domiciled and cause of action arose within the jurisdiction of
    this Honourable Court.

    4. On the 17th September 2010, and at or near Grootfontein, Otjozondjupa


    Region, Republic of Namibia, the parties were married to each other out of
    community of property which marriage still subsists. A copy of the parties’
    marriage certificate is attached hereto marked “1”.

    5. One minor child was born from the marriage between the parties to wit:

    5.1. Ngunzi Kambinda Rogger a boy child, born on 10 February 2008.

    6. The minor children are currently in the care and custody of the Defendant. It
    would, thus, be in the best interests of the minor children if custody and
    control of such children is awarded to Defendant, subject to Plaintiff’s rights of
    reasonable access.
    Page |2

    7. During the subsistence of the marriage and with the fixed and malicious intent
    to terminate the marital relationship between the parties, defendant acted in
    the following wrongful and/ or unlawful manner:

    7.1. The Defendant shows no love and affection towards the Plaintiff.
    7.2. Elicits unnecessary fights and quarrels with plaintiff
    7.3. Failed to communicate meaningfully with plaintiff
    7.4. As a result of defendants wrongful conducts mentioned in 7.1 to 7.3
    above, the parties grew apart and plaintiff moved out of the common
    home with her personal belongings in 2023.
    7.5. He shows no intention to continue with the marriage

    8. As a result of defendant’s aforesaid wrongful conducts, the parties herein have


    not lived together as husband and wife for more than 11 years.

    9. In the premise, defendant has, in an intentional, wrongful and/ or unlawful


    manner constructively and/ or maliciously deserted the Plaintiff, in which
    desertion he persists.

    WHEREFORE, the Plaintiff prays for the following:

    1. (a) Restitution of Conjugal Rights and failing compliance therewith;

    (b) A final order of divorce;

    2. An order in terms whereof custody and control of the minor children is


    awarded to Defendant, subject to Plaintiff’s rights of reasonable access;

    3. Cost of suit (only if defended);

    4. Further and /or alternative relief.

    DATED AND SIGNED AT OSHAKATI ON THIS 24th DAY OF JUNE 2024.


    Page |3

    _________________________
    MARGARETH KAKUVA
    OSHAKATI,
    OSHANA REGION
    NAMIBIA

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