Examination And Cross Questions

Summary

In a breach of contract case involving the Uganda Coffee Development Authority, the plaintiff, a coffee nursery operator, claims non-payment for supplied seedlings. Examination questions focus on the plaintiffs role, contract details, and efforts to obtain payment. Cross-examination questions address payment confirmation, demand evidence, and potential disputes.

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I would like cross examination questions from opposing counsel for my witness statement I, Teopista Nassuna, of c/o M/s. F5 & Co. Advocates, Plot * Kyamugorani, Mbarara, being a female adult Ugandan of sound mind and the Plaintiff in this suit, make this statement in support of my case and state as follows: *. I am Teopista Nassuna, aged 30 years, a businesswoman and coffee nursery operator. *. That in *, I became aware of a Government of Uganda program called Operation Wealth Creation (OWC), which aims to uplift household incomes. The program includes, among other initiatives, the distribution of coffee seedlings to farmers in selected districts. This program was implemented by the Uganda Coffee Development Authority (UCDA) in collaboration with various local government officers. *. That I enrolled in the Coffee Seedling project under OWC and signed a contract to supply *,* coffee seedlings to designated farmers in various selected districts. The contract details are documented in the purchase order, a copy of which is attached and marked as “Annexure B.” *. That Coffee Nursery Operators, including myself, were assigned to supply coffee seedlings as per the allocation list provided by UCDA. A copy of this allocation list is attached and marked as “Annexure A.” *. That pursuant to the terms of the contract, I supplied *,* coffee seedlings to the beneficiaries in accordance with the distribution form attached and marked as “Annexure C.” *. Since fulfilling my contractual obligations by delivering the coffee seedlings, I have made several demands for payment of the agreed amount, totaling UGX *,*,* (Uganda Shillings One Hundred Fifty-Seven Million Five Hundred Thousand Only). *. That in the process of transporting the coffee seedlings, I incurred transport costs as well totaling to Ugx *,*,*/= (Uganda Shillings Three Million Five Hundred Thousand) only. *. Despite my numerous demands, the Defendant has failed to pay the amount owed, causing significant financial and emotional distress. *. That the Defendant, Uganda Coffee Development Authority (UCDA), has breached the contract by failing to pay for the supplied coffee seedlings within the agreed timeframe. As a result of this breach, I have suffered losses, including lost income that I would have earned had the payment been made on time. Furthermore, the delayed payment has caused me mental anguish and stress from repeatedly demanding payment in vain. *. That I seek the intervention of this Honorable Court to assist me in recovering the amount owed, along with interest, special damages, general damages as outlined in my plaint. *. That I make this statement believing the same to be true to the best of my knowledge and understanding.
Here are some potential cross-examination questions:
*. Did you receive any written confirmation from UCDA regarding the exact timeline for payment?
*. Can you provide specific dates and evidence for the demands you made for payment?
*. Were there any disputes or issues raised by the beneficiaries about the quality or quantity of the coffee seedlings supplied?
*. Did you incur any other costs not mentioned in your statement?
*. Have you considered any other form of resolution before approaching the court?
Would you like to know more about any particular legal aspect of your case?