Wilfred Phiri is suing Bambo Mainza for damages arising from a road accident. On a rainy Monday afternoon of 10 January 2004 Bambo Mainza was riding his motorcycle along Nsumbu road in Lusaka when suddenly he hit a pot hole that was full of rain water and lost control. He ran into Wilfred Phiri who was walking on the side of the road with four full crates of imported pears on his head. As a result of the accident all the pears were destroyed and Wildred Phiri demanded Bambo Mainza compensate him. The pears cost K1,650,000. Bambo Mainza refused to pay saying it was not his fault because there was no way of him knowing that there was a pot hole on the road as it was full of water and there was no warning sign on the road. His motorcycle was also damaged beyond repair. Bambo Mainza has refused to accept responsibility and has asked you to defend him. Assuming you have given the correct legal advice to Bambo Mainza, draft the legal documents you would file that will best suit your client's defence in line with the provisions of the Subordinate Courts Act of Zambia and give traceable citations.