Your client is served with a combined summons on 5 December 2022 and consults you to defend the action. Considering the contents of particulars of claim below, advise your client on the immediate options. Consider and refer in your answer to all options available to your client, decide on the one best suited for your client's case, and draft the relevant documents to give effect to your decision. Motivate the step/s you do decide to take. (20 marks)

PARTICULARS OF CLAIM

1. The PLAINTIFF is JOE SOAP, a major male person resident at no. 10 XYZ Street, Windhoek, Republic of Namibia.

2. The DEFENDANT is JANE UNFORTUNATE, a major female person resident at no. 20 ABC Street, Windhoek, Republic of Namibia.

3. On or about 10 October 2001 the defendant and ABC Industrials CC entered into a written agreement.

4. In terms of the agreement the defendant was obliged pay an amount of N$250,000.00 to the plaintiff by no later than 30 November 2006.

5. The defendant failed to make payment as aforesaid.

6. In the premises the defendant is indebted to the plaintiff in the amount of N$500,000.00.

W H E R E F O R E the plaintiff prays for judgment against the defendant in the following terms:

1. Payment in the amount of N$500,000.00.

2. Interest on the aforesaid amount at the rate of 20% per annum a tempore morae.

3. Costs of suit.

4. Further or alternative relief