10. Ad Para 4.5.8- 4.5.10 This is denied. 10.1. The applicant once again makes bald and general averments without producing any proof before the court of his averments. Whilst averring that ZANU PF has refuted any allegations that it obtained voters’ cell phone numbers from the 23rd respondent the applicant dismisses the refutation with no evidence apart from his own belief that the only possible source of the cell phone numbers was the 23rd respondent. Contrast this with how he readily accepts the refutation by cell phone service providers with no greater evidence than the same type of refutation that was done by ZANU PF. 10.2. For the avoidance of doubt, the Zimbabwe Electoral Commission does not, and has never shared confidential voter information such as voter cell phone numbers with any political party. The Electoral Commission issued a press statement making this clear, which I attach hereto marked Annexure ‘A’. As the applicant makes a contrary assertion, it was incumbent upon him to present the proof for such assertion in his founding papers. He has failed to do so. 10.3. Further, every voters’ roll provided to political parties or to any member of the public in terms of the law, contains the addresses of the voters registered thereon. 10.4. By affidavit in opposition to an urgent chamber application filed by one Sikhumbuzo Mpofu, HC6545/18, which matter relates to the allegation that the