01notice of motion Page 1 of 3 IN THE CONSTITUTIONAL COURT OF SOUTH AFRICA
CC CASE NO: ___________
In the matter between:
MUYIWA GBENGA-OLUWATOYE Applicant
and:
RECKITT BENCKISER SOUTH AFRICA (PTY) LIMITED First Respondent
NADEEM BAIG, N.O. Second Respondent
NOTICE OF MOTION
BE PLEASED TO TAKE NOTICE that the Applicant hereby applies to the Constitutional Court for an Order in the following terms:
1. Granting the Applicant Leave to Appeal against the whole of the Judgment and Order of the Labour Appeal Court (Coram: Waglay JO, Coppin JA et Savage AJA) dated 03 February 2016 under Labour Court Case No.
J580/2014; and
2. Granting the Applicant further and/or alternative relief.
01notice of motion Page 2 of 3 TAKE NOTICE FURTHER that the attached Founding Affidavit of NDUMISO PEDRO VOYI will be used in support of this Application.
TAKE NOTICE FURTHER that the Respondents herein may within 10 (ten) days of receipt of hereof respond by Affidavit indicating whether they consent to leave being granted and, if the Application is opposed, their grounds for opposition.
AND FURTHER TAKE NOTICE that the Applicant has appointed the address of his attorneys of record, as set out below, as the address at which he will accept service of all notices and process in this Application.
SIGNED AT MIDRAND ON THIS ______ DAY OF FEBRUARY 2016.
______________________________
NDUMISO VOYI INCORPORATED APPLICANT'S ATTORNEYS
GROUND FLOOR, BUILDING 5 MIDRAND BUSINESS PARK 563 OLD PTA MAIN ROAD HALFWAY HOUSE, MIDRAND TEL : (011) 312 7537/8 FAX : (086) 246 2216 REF : N P VOYI/AH
CARE OF: NDHLOVU AJ INC.
ATTORNEYS
6TH FLOOR, JHC BUILDING 51 MAIN STREET
JOHANNESBURG TEL: 011-315-5335
FAX: 011-838 4370 / 086 559 6913 REF: MR NDHLOVU
01notice of motion Page 3 of 3 TO:
THE REGISTRAR OF
THE CONSTITUTIONAL COURT JOHANNESBURG
DELIVERY BY HAND
AND TO:
CLIFFE DEKKER HOFMEYR RESPONDENTS’ ATTORNEYS 1 PROTEA PLACE
SANDOWN, 2196
TEL : (011) 562 1159 FAX : (011) 562 1624
EMAIL : [email protected] REF : MR C J BOTES
RECEIVED copy hereof on this _____
day of FEBRUARY 2016
_______________________________
FOR: RESPONDENTS’ ATTORNEYS