This is a highly specific legal drafting request. I will proceed with the assumption that \"Paul\" is the **Respondent/Defendant** in a matter where the Applicant/Plaintiff is seeking a **Stay of Proceedings** (or an interim injunction pending a final hearing), and that Paul opposes this stay.\n\nBecause you have not attached the specific documents, I will construct a **template** based on standard legal principles for opposing a stay (e.g., delay, balance of convenience, no serious question to be tried, or abuse of process). You must **fill in the bracketed details** with the actual facts from your documents.\n\n---\n\n### PART 1: REVISED AFFIDAVIT OF PAUL\n\n**IN THE [NAME OF COURT]**\n**BETWEEN:**\n**[APPLICANT NAME]** – Applicant\n**AND**\n**PAUL [SURNAME]** – Respondent\n\n**AFFIDAVIT OF PAUL [SURNAME]**\n**Sworn on: [Date]**\n\nI, **Paul [Surname]**, of [Address], [Occupation], **MAKE OATH AND SAY** as follows:\n\n**1. INTRODUCTION AND PURPOSE**\n1.1 I am the Respondent in this matter. I have personal knowledge of the facts deposed to herein, save where stated otherwise, which I verily believe to be true.\n1.2 I make this Affidavit in opposition to the Applicant’s Notice of Motion dated [Date] seeking a Stay of Proceedings pending [reason for stay, e.g., appeal / arbitration / further discovery].\n1.3 I submit that the Application for a Stay is **dilatory, without merit, and constitutes an abuse of process**. The Applicant has failed to establish the requisite grounds for a stay.\n\n**2. CHRONOLOGICAL BACKGROUND OF THE DISPUTE**\n2.1 **On [Date 1]**, the parties entered into a written agreement for [describe contract, e.g., sale of goods / services]. A copy is annexed hereto as “**P-1**”.\n2.2 **On [Date 2]**, the Applicant breached the agreement by [specific breach, e.g., failing to pay the deposit / delivering defective goods].\n2.3 **On [Date 3]**, I issued a formal letter of demand. The Applicant ignored this demand. A copy is annexed as “**P-2**”.\n2.4 **On [Date 4]**, I filed the current proceedings to protect my rights.\n2.5 **On [Date 5]**, the Applicant filed a Defence. Notably, the Defence did not raise the grounds now relied upon for the Stay.\n2.6 **On [Date 6] (Last Week)**, the Applicant filed the current Stay Application. This is the first time the Applicant has mentioned [ground for stay, e.g., a pending arbitration clause / ill health / lack of jurisdiction].\n\n**3. FACTUAL AND LEGAL ARGUMENTS AGAINST THE STAY**\n\n**3.1 The Application is Grossly Delayed (Laches)**\n3.1.1 The Applicant knew of the alleged grounds for a stay (e.g., the arbitration clause) since [Date 1] when the contract was signed.\n3.1.2 Despite this knowledge, the Applicant waited **[X months/years]** and only filed for a stay **after** I had incurred significant legal costs and after the matter was set down for trial.\n3.1.3 This delay is inexcusable. A stay at this stage would severely prejudice me. I have already paid my lawyers a non-refundable brief fee of $[Amount].\n\n**3.2 No Serious Question to be Tried / No Prima Facie Case for a Stay**\n3.2.1 The Applicant’s founding affidavit is bare and lacks detail. The Applicant merely states that a stay is “necessary” but provides no evidence of irreparable harm.\n3.2.2 Conversely, I have a strong *prima facie* case. The contract (P-1) is clear. The Applicant’s own emails (annexed as “**P-3**”) admit liability.\n3.2.3 The Applicant has no bona fide defence. The stay is merely a tactic to delay payment.\n\n**3.3 Balance of Convenience Favors Refusing the Stay**\n3.3.1 If the stay is granted, I will suffer immediate financial hardship. I rely on the sum claimed to pay my [mortgage / business expenses].\n3.3.2 The Applicant will suffer no prejudice if the matter proceeds. The Applicant is a large corporation with ample resources.\n3.3.3 The Applicant has offered no undertaking as to damages. This is fatal to their application.\n\n**3.4 The Applicant has Unclean Hands**\n3.4.1 The Applicant has failed to comply with previous court orders regarding discovery (see Order dated [Date]).\n3.4.2 The Applicant is currently in contempt of court for failing to pay an earlier costs order.\n\n**4. CONCLUSION**\n4.1 The Applicant has failed to meet the three-part test for a stay: (a) a serious question to be tried; (b) balance of convenience; and (c) irreparable harm.\n4.2 I respectfully submit that the Application should be dismissed with costs on an attorney-and-client scale due to the Applicant’s delay and bad faith.\n\n**SWORN** at [Location] )\nthis [Day] day of [Month] 2026 )\n\nBefore me: )\n_____________________________\n**COMMISSIONER OF OATHS**\n\n---\n\n### PART 2: SUBMISSIONS FOR THE INTERIM DEFENDED HEARING / STAY APPLICATION\n**Court Date: Tuesday, 12th May 2026 at 4:00 PM**\n\n**Scenario:** You are Paul’s lawyer. The Judge will ask you to speak. Below is your **script / submission outline**. Speak clearly, slowly, and refer to the Affidavit above.\n\n---\n\n**“May it please Your Honour.**\n\n**I appear for the Respondent, Paul. My friend appears for the Applicant.**\n\n**Your Honour, this is the Applicant’s application for a Stay of Proceedings. We oppose it vigorously.**\n\n**Your Honour, I rely on the Affidavit of Paul sworn on [Date]. I adopt that as my submission.**\n\n**Let me address the Court on three points: Delay, Prejudice, and Lack of Merit.**\n\n**First: Delay.**\nYour Honour, the Applicant knew of the alleged grounds for this stay since [Date of Contract]. They filed a Defence. They attended case management. They did nothing. They only filed this application last week, on the eve of trial. This is a textbook case of laches. The Applicant cannot now seek equity when they have slept on their rights. I refer Your Honour to the case of *[Case Name]* regarding delay in stay applications.\n\n**Second: Prejudice.**\nYour Honour, my client has spent $[Amount] in legal fees. The Applicant has offered no undertaking as to damages. If we grant a stay, my client is left holding a judgment that cannot be enforced for months or years. The balance of convenience lies squarely with my client, who simply wants his day in court.\n\n**Third: No Serious Question.**\nYour Honour, the Applicant’s founding papers are hollow. They say a stay is needed for [reason]. But they have provided no evidence of irreparable harm. My client, on the other hand, has a clear contract and an admission of liability. There is no serious question to be tried regarding the stay itself.\n\n**Your Honour, I submit that this application is an abuse of process. It is a delaying tactic.**\n\n**We ask for the following orders:**\n1. That the Applicant’s Notice of Motion dated [Date] be dismissed.\n2. That the matter proceed to trial as scheduled.\n3. That the Applicant pay the costs of this application on a punitive scale, being attorney-and-client costs, due to the unreasonable delay.\n\n**Unless I can assist the Court further, those are my submissions.”**\n\n---\n\n### Important Notes for You (Paul):\n\n1. **Fact-Checking:** You must replace the bracketed `[Date]`, `[Amount]`, and `[Case Name]` with the exact facts from your documents. If the Applicant’s delay was 3 months, say 3 months. If it was 2 years, say 2 years. Precision is key.\n2. **Exhibits:** You must attach the documents you refer to (P-1, P-2, P-3). If you don't have them, the Judge will not believe you.\n3. **The \"Stay\" vs \"Interim Defended Hearing\":** A \"Stay Application\" is usually heard at an \"Interim Defended Hearing\" (IDH). The above script works for both. The Judge will decide if the case should be paused (stay) or kept moving.\n4. **Time Limit:** You have until **4:00 PM on Tuesday, 12th May 2026**. You must file the Affidavit and Submissions (or Notice of Opposition) with the Court and serve them on the Applicant's lawyer **before that deadline**.\n\n**If you provide the specific documents (the contract, the delay dates, the amount of money), I can rewrite this with 100% accuracy for your specific case.**