i. The allegations pleaded are vague and are in generalized terms; ii. The alleged breaches of the constitution have not been pleaded with sufficient material particularity; iii. No particulars have been pleaded regarding the Speaker’s actions which were without jurisdiction or in excess of her jurisdiction; iv. That part 40(1)(d) of the Constitution is a permissive section and the alleged breaches in paragraph 29(2) does not establish any rights which have been breached. v. That no particulars have been stated or no possible violation of Section 35(1) of the Constitution have been pleaded in paragraph 28 (2) of the affidavit in support of the claim. vi. That the alleged breach of section 8(8) of the Constitution at paragraph 28(4) is misconceived and discloses no cause of action. That the Claimant has not given any particulars of Laws or pleaded any material facts which could establish that the Speaker of the House is an authority prescribed by law for the determination of any civil right or obligation and that any proceeding for determination were instituted for determination by any person before such authority. c. That by-elections were held, the Claimant was re-elected to the House of Assembly on the 10th July 2010 and therefore the claims or parts thereof should be struck off as being merely academic or moot.  d. That Standing Order 15(2) specifies in what circumstances a member’s seat becomes vacant by operation of law and based on the statements made by the Claimant in his affidavit the circumstances existed which would have the effect in law of making the seat vacant. e. That any challenge by the Claimant against the by election could only be challenged by means of an elections petition.   8