On 1 December 2007, Tyson Banda who carries out the business of money lender, lent out K26,000,000 to one Jane Ngupeni, a cross border trader operating from Comersa market, Lusaka. The 2 parties executed a written agreement wherein Jane Ngupeni undertook to repay the principal sum of K26,000,000 with interest at the rate of 30 % per annum by the 31 day of August 2008. On the due date Jane requested an extension of 2 weeks within which to liquidate the indebtedness but due to financial constraints she failed to honour undertaking thereby prompting Mr Banda to commence legal proceedings by way of Default Writ of Summons through your chambers which Summons were duly served on Jane. Five days before the date set for commencement of trial Mr Banda informs you that Jane is about to flee the country with intent to obstruct or delay the execution of judgement that may be passed against her. Mr Banda is desperate to recover his money from Jane and accordingly instructs you to do everything possible to ensure that Jane does not flee the country before the Court adjudicates on the matter.
With the aid of relevant law applicable to summons in Zambia, draft the Summons, supporting Affidavit and one other relevant document you would file into the subordinate Court.