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The Affidavit

An affidavit is a statement made under oath that some fact, or set of facts, is true to the best of the knowledge of the person signing the affidavit, or the affiant. Affidavits are commonly used to transfer property and provide sworn statements to Courts and other government agencies.

Describe the facts to which the affiant will swear. You may include as many or as few facts in an affidavit as necessary. When describing the facts you should: State each one in a separate paragraph. Each paragraph of the affidavit should include one fact or a small number of facts if one cannot be stated alone.

Number your paragraphs. This will make for easier reading and reference in Court or other documents.

Describe each fact clearly and concisely, providing names, dates, addresses, and other supporting information as needed.

Reference supporting documents, photographs, or other tangible paper items which can be attached to the affidavit, and attach them. For example, if describing a photograph in the affidavit, state that a copy of the photograph is attached and marked as “exhibit A” then write “exhibit A” on a copy of the photograph and staple it to the completed affidavit. Exhibits may be lettered or numbered, whichever you prefer, and should be labeled according to the order in which they are mentioned in the affidavit i.e. the first exhibit mentioned should be labeled A or 1, the second B or 2, and so on.

Make a clear statement that the affidavit is a complete representation of the facts to which the affiant is swearing. This is to ensure readers that the affidavit is not a partial statement and that it includes all of the information the affiant has on the subject.

Be as brief as you can, while making sure to include all relevant information.

By signing the affidavit, the subject is making an oath of honesty. All facts within the document must be true. If they are found to be false, the person making the statement may be punishable by law and guilty of contempt of court.

What is an Affidavit, it is explained HERE the form [affidavit] you need is HERE, download the document and write out your affidavit.

The format for your affidavit can be seen here, don’t just copy it, write your own.


Record No: 2009, No 14099SP


GE Capital, Woodchester Home Loans LTD

as [was] registered company 34927

Now known as Pepper Asset Servicing






I, Byron XXXXX of XXX Colbinstown, County Kildare, aged 18 years and upwards MAKE OATH and say as follows:-

1. I am a co-defendant in the above entitled matter. I make this Affidavit from facts within my own knowledge save where otherwise appears and where so otherwise appearing I believe the same to be true.

2. I beg to refer to the pleadings and proceedings already had herein when produced. I make this Affidavit in reply to the Affidavits filed on behalf of the Plaintiff herein.

3. I say that on or about the 16th May 2008 my wife XXXX XXXX and I secured a mortgage with the Plaintiff herein in respect of the property XXXXXX, Colbinstown, Co. Kildare, hereinafter referred to as ‘the Family Home’.

4. I do beg as co Defendant state that: the Plaintiff, known as GE Woodchester Home Loans Ltd [co registered 34927] sold the Mortgage file, via a special purpose Vehicle to Pepper Asset Servicing, The Defendant questions the legality of this third party to collect, after all they [Pepper Asset Servicing] are simply a debt collection agency which, we have not agreed to or consented to do business with. Whilst the Plaintiff is pursuing this court case, by their own admission, they no longer own the Mortgage having been paid by Pepper Finance (H62), company Registration 286004 & 37043 Pepper Finance Corporation (Ire) Ltd and having assumed the name and trading under Pepper Asset Servicing, registration [was GE Woodchester Home Loans Ltd] 34927, the registered company the Defendants contract is with.

Exhibit –A- Letter from Pepper Asset Servicing.

5. I beg to inform the Court that any written correspondents are and were addressed to GE Money, GE Woodchester, including ‘registered’ post. All post was opened and replied to by Pepper Asset Servicing. The Plaintiff, GE Capital Woodchester Home Loans are no longer in this island of Ireland, having simply changed the name of the company, Directors and Secretary. The Defendants expresses concern that while the “Defendant” was in no better a position to proceed due to the lack of communication with the actual “Plaintiff” the matter is compounded by the fact that the “Plaintiff” does not appear to have any standing in the Court by virtue of the statement made, Exhibit –B-. In absolutely unambiguous language, in the letter referred to above, in short, why are they pursuing this matter as an injured party when they clearly state that they are no longer an injured party!

Exhibit –B- Letter from GE Woodchester Home Loans Ltd.

Exhibit – F- Letter from Pepper

Exhibit – D- Letter to GE Woodchester Home Loans

and Pepper Asset Servicing dated 16 day of April 2013.

6. The “Defendant” maintains that while there might well be an entity out there who alleges they are due money on the basis of this facility, that entity was not in Court!

Exhibit –C- Letter from GE Woodchester Home Loans Ltd.

7. The Defendant would also bring to the attention of this honourable court the contents of a letter dispatched to the Plaintiffs posing certain question which, the Defendant deems relevant to the whole position of the mortgage and its legality. Exhibit –E- was never answered.

Exhibit –E- registered Letter, dated 16th day of April 2013

The Co-Defendants would therefore prey this Honourable Court to enquire if the Plaintiff could find the so called, ‘injured party’, for the defendants to engage with.

The Co-Defendants would also prey this Honourable Court to instruct the Plaintiffs to produce the evidence that the Defendants mortgage is in fact owned by either of the Plaintiffs.

Should this not be possible the Defendants prey this Honourable Court move to have this case thrown out of this Honourable Court.

Dated this day of 2013


Defendant or Solicitor for