Discovery affidavit – High Court – Form 11 of the First Schedule of the Uniform Rules – Uniform Rule of Court 35(2)

The party required to make discovery in terms of Uniform Rule 35(10 shall within twenty days or within the time stated in any order of a judge make discovery of such documents on affidavit as near as may be in accordance with Form 11 of the First Schedule, specifying separately-

(a) such documents and tape recordings in his possession or that of his agent other than the documents and tape recordings mentioned in paragraph (b);
(b) such documents and tape recordings in respect of which he has a valid objection to produce;
(c) such documents and tape recordings which he or his agent had but no longer has in his possession at the date of the affidavit.

A document shall be deemed to be sufficiently specified if it is described as being one of a bundle of documents of a specified nature, which have been initialled and consecutively numbered by the deponent. Statements of witnesses taken for purposes of the proceedings, communications between attorney and client and between attorney and advocate, pleadings, affidavits and notices in the action shall be omitted from the schedules.