IN THE HIGH COURT OF LAGOS STATE
IN THE IKEJA JUDICIAL DIVISION
HOLDEN AT IKEJA
SUIT NO: ID/ADR/223/15
BETWEEN
SAM OMATSEYE ”¦”¦”¦ CLAIMANT
AND
THE SUN PUBLISHING LIMITED ”¦”¦”¦. DEFENDANT
(Publishers of the Daily Sun)

STATEMENT OF CLAIM
1. The Claimant is the Chairman of The Nation newpaper’s Editorial Board; a graduate of History from University of Ife (now Obafemi Awolowo University), Ile-Ife.

2. The Defendant is the proprietor and publisher of a popular newspaper called Daily Sun which enjoys wide circulation and readership in Nigeria and abroad.

CLAIMANT’S CREDENTIALS
3. The Claimant avers that he is a poet, playwright, novelist, journalist and columnist of many years standing and has distinguished himself in all these fields of human endeavours over the years.

4. The Claimant avers that he has lectured in Metropolitan State College, Denver, University of Colorado and University of Denver in United States of America.

5. The Claimant avers that far back in 1991, he was the first winner of the Gordon N. Fisher Fellowship for Journalist in the Commonwealth by the Southam Foundation based in Toronto, United States of America.

6. The Claimant avers further that he has also won the Alfred Friendly Press Fellowship in United States during which he was a recipient of the Scripps Howards Prize for deadline reporting with the Rocky Mountain News in Denver.

7. The Claimant in addition avers that he is a winner of the Scribes in Excellence Prize for feature writing for the Association of Black Journalists in the United States.

8. The Claimant avers that he is a four-time winner of the Nigeria Merit Award, once in the reporter category and three times as a columnist of the year.

9. The Claimant avers that he also won the informed category of Diamond Award for Media Excellence three times.

10. The Claimant avers that he is a member of the Governing Council, Lagos State University, Ojo and also an Honorary Fellow, Nigeria Academy of Letters, Lagos.

11. The Claimant further avers that as a result of his exceptional career, he has received several awards and commendations from organisations across the nation and beyond and he is recognized as a leading light on Nigeria’s fight against corruption.

LIBEL AGAINST THE CLAIMANT
12. The Claimant further avers that in its Daily Sun Newspaper of Tuesday, 13th October, 2015, the Defendant falsely and maliciously caused to be printed and published the following words of and concerning the Claimant:

“CALL OMATSEYE TO ORDER, KALU TELLS TINUBU”¦.SAYS THE NATION EMBARRASSMENT TO JOURNALISM”

13. The Claimant further avers that at page 7 of Daily Sun Newspaper of Tuesday, 13th October, 2015, the Defendant falsely and maliciously caused to be printed and published the following words of and concerning the Claimant as an elaboration of the above stated headline:

““We wonder how a supposedly seasoned writer and Editorial Board Chair could not distinguish between propaganda and purely professional reportage in his pecuniary bohemianism. This is indeed unprofessionalism demonstrated by rascally Omatseye”

“”¦.In any case, is Omatseye saying that Tinubu, as the publisher of The Nation, determines what the newspaper publishes? If that is the convention in his organization, it is an entirely different case in The Sun and New Telegraph titles, as Kalu has never interfered in the editorial policy and content of the titles in his newspaper establishments.

“In addition, for purposes of argument, even if that was the routine, it is not against the ethics of journalism for publishers to kill stories as expected by Omatseye, who knows full well that Kalu does not meddle in his publications?

“We sympathize with brazen Omatseye on grounds of his not being a trained journalist or even a news reporter so as to understand the distinction between the news reporting and poetry, which incapacitates his knowledge of the rudiments of the calling which all mass communication sophomores know. It is also unfortunate that since Omatseye returned from America and was rehabilitated by a few past and present governors, he has turned himself to a rabid defence dog for his new benefactors”

“It may equally interest Omatseye to know, if his bovine intelligence will allow him, that Kalu and Tinubu enjoy cordial relationship spanning over three decades. It is Omatseye’s intemperate use of language that almost put him in trouble when he scurrilously and irresponsibly attacked Chief Awolowo clan all in his characteristic self-assignation of worming himself to Tinubu for more survivalist packages”¦”

14. The Claimant hereby pleads and shall rely on a copy of the Daily Sun Newspaper containing the libellous materials at the trial of this suit.

NATURAL AND ORDINARY MEANING OF THE DEFAMATORY WORDS
15. The said words in their natural and ordinary meaning (by direct reference and innuendos) meant and were understood to mean that:

(a) The Claimant is a charlatan, an impostor and fake personality.
(b) The Claimant is a dubious person whose stock in trade is sycophancy and dishonesty.
(c) The Claimant is a mudslinging and dangerous personality.
(d) The Claimant is a corrupt and uncivilized person.

16. The Claimant avers that the libellous publication by the Defendant was widely circulated and read by millions of people in the world and particularly in Nigeria where the Claimant has several associates, friends, family and professional colleagues.

17. The Claimant avers that by reason of the publication of the words set out in paragraph 13 above and their import set out in paragraph 14, the Claimant has been seriously injured in his character, credit, reputation and integrity and has been brought to public scandal, odium and contempt and has suffered damages.

PUBLICATION OF THE LIBELOUS MATERIALS BY THE DEFENDANT

18. The Claimant avers that the libellous materials as shown in “the Daily Sun” was published in the ordinary course of business and accordingly offered for sale to the public.

19. The Daily Sun newspaper circulates in Lagos which is within the jurisdiction of this Honourable Court and around the entirety of the Federal Republic of Nigeria and beyond.

20. The Claimant avers that the Defendant has an online platform that enables readers’ access their publications anywhere in the whole world.

21. The Claimant shall contend at the trial that the action of the Defendant was motivated by malice and with intent to undermine and malign the goodwill and popularity enjoyed by the Claimant.

22. The Claimant avers that the Defendant knows that the libellous publications are untrue, unfounded and cannot be substantiated.

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23. The Claimant further avers that immediately after the publication was released, he received numerous telephone calls from professional colleagues, international associates, multinational organisations, relations, friends and religious leaders expressing their utmost disgust and contempt at the Claimant’s alleged disgraceful, unpatriotic and sacrilegious conducts and questioned the integrity of the Claimant.

24. The Claimant avers that the spurious allegations made by the Defendant are untrue and actuated by malice with intent to malign and undermine the Claimant’s reputation.

PARTICULARS OF MALICE
(a) The allegations in the publication are false and untrue.
(b) The Defendant did not conduct any investigation into the truthfulness of the allegations before publishing them.
(c) The Defendant did not offer the Claimant any opportunity to respond to the allegations before publishing them.
(d) By publishing the allegations in a sensational screaming caption, the Defendant evinced the intention to malign the Claimant and drag his reputation in the mud.

25. The Claimant shall rely on the following facts in support of his claim for damages including exemplary damages.

a. The defamatory words were published in a sensational manner.
b. The Defendant knows or ought to have known that the allegations were untrue and totally unfounded.
c. The Defendant has at the time of instituting this action failed to retract the defamatory statements.
d. The court would be asked to infer that the Defendant published the said words:

i. In the knowledge that they were libellous and/or with reckless disregard as to whether or not they were libellous.
ii. In the belief and calculation that they would injure and damage the Claimant’s reputation.
26. The Claimant avers that he has suffered tremendous damage to his reputation and if the Defendant is not restrained, it will further publish injurious articles against the Claimant.
WHEREFORE, the Claimant claims against the Defendant as follows:
1. A DECLARATION that the publication referred to in paragraph 13 of the Statement of Claim is libellous of the Claimant.

2. AN ORDER for the sum of N1,000,000,000.00 (One Billion Naira) only being damages for the words published of and concerning the Claimant which are libellous by direct reference and innuendo contained at page 5 of the New Telegraph of 13th October, 2015 titled ”˜CALL OMATSEYE TO ORDER, KALU TELLS TINUBU”¦SAYS THE NATION MAN EMBARRASSMENT TO JOURNALISM’.

3. AN ORDER of the Honourable Court for a retraction and an unreserved apology by the Defendant for the words published of and concerning the Claimant which are libellous and contained at page 7 of the Daily Sun of 13th October, 2015 titled ”˜CALL OMATSEYE TO OREDR, KALU TELLS TINUBU”¦SAYS THE NATION MAN EMBARRASSMENT TO JOURNALISM’

4. AN ORDER OF PERPETUAL INJUNCTION restraining the Defendant whether by itself, its agents, privies or servants from further publishing or causing to be published any libellous, injurious or defamatory words against the Claimant.

5. FOR SUCH FURTHER ORDER OR OTHER ORDERS as this Honourable court may deem fit to make in the circumstances of this case.
Dated 22nd day of October, 2015.

FESTUS KEYAMO, ESQ.,
UCHENNA B. MONEKE, ESQ.,
CLAIMANT’S COUNSEL,
FESTUS KEYAMO CHAMBERS,
1, FESTUS KEYAMO LANE,
OFF ADEBAYO MOKUOLU, STREET,
OFF GBAGADA EXPRESSWAY,
BEHIND HOTEL NEWCASTLE,
ANTHONY VILLAGE,
LAGOS STATE.
08055028515, 08033371229
festuskeyamochamberslag@yahoo.com

FOR SERVICE ON DEFENDANT

DAILY SUN PUBLISHING LIMITED,
NO. 2, COSCHARIS STREET,
OFF HAPPYHOME AVENUE,
KIRIKIRI INDUSTRIAL LAYOUT,
APAPA,
LAGOS STATE.

FORM 1
(O. 3 r. 3)
FORM OF WRIT OF SUMMONS
IN THE HIGH COURT OF LAGOS STATE
IN THE IKEJA JUDICIAL DIVISION
HOLDEN AT IKEJA
SUIT NO: ID/ADR/223/15
BETWEEN:
SAM OMATSEYE ”¦”¦”¦ CLAIMANT

AND
THE SUN PUBLISHING LIMITED ”¦”¦”¦ DEFENDANT
(Publishers of the Daily Sun)

TO: THE DEFENDANT of No. 2, COSCHARIS STREET, OFF HAPPYHOME AVENUE, KIRIKIRI INDUSTRIAL LAYOUT, APAPA, LAGOS STATE.

LAGOS

HIGH COURT OF LAGOS STATE

in the …………………………….. Judicial Division of………………………………………………….
CLAIMANT

You are hereby commanded that within forty-two days after the service of this Writ on you, inclusive of the day of such service, you do cause an appearance to be entered for you in an action at the Suit

of…………………………………………………………………………………………………………………… and take notice that in default of your so doing the Claimant(s) may proceed therein, and judgment may be given in your absence.
Dated 22nd day of October, 2015.
……………………………….
REGISTRAR

Memorandum to be subscribed on the writ.

N.B. This Writ is to be served within six calendar months from the date thereof, or, if renewed within three calendar months from the date of the last renewal, including the day of such date, and not afterwards.

The defendant may enter appearance personally or by legal practitioner either by handing in the appropriate forms, duly completed, at the Registry of the High Court in which the action is brought or by sending them to the Registrar by registered post.

WHEREOF the Claimant claims against the Defendant as follows:
1. A DECLARATION that the publication referred to in paragraph 13 of the Statement of Claim is libelous of the Claimant.

2. AN ORDER for the sum of N1,000,000,000.00 (One Billion Naira) only being damages for the words published of and concerning the Claimant which are libelous by direct reference and innuendo contained at page 5 of the New Telegraph of 13th October, 2015 titled ”˜CALL OMATSEYE TO ORDER, KALU TELLS TINUBU”¦SAYS THE NATION MAN EMBARRASSMENT TO JOURNALISM’.

3. AN ORDER of the Honourable Court for a retraction and an unreserved apology by the Defendant for the words published of and concerning the Claimant which are libelous and contained at page 7 of the Daily Sun of 13th October, 2015 titled ”˜CALL OMATSEYE TO OREDR, KALU TELLS TINUBU”¦SAYS THE NATION MAN EMBARRASSMENT TO JOURNALISM’

4. AN ORDER OF PERPETUAL INJUNCTION restraining the Defendant whether by itself, its agents, privies or servants from further publishing or causing to be published any libelous, injurious or defamatory words against the Claimant.

5. FOR SUCH FURTHER ORDER OR OTHER ORDERS as this Honourable court may deem fit to make in the circumstances of this case.

This writ was issued by UCHENNA B. MONEKE, ESQ.,. of FESTUS KEYAMO CHAMBERS

Whose address for service is 1, FESTUS KEYAMO LANE, OFF MUKUOLU STREET, BEHIND HOTEL

Alleged Libel: The Nation’s Editorial Board Chairman, Omatseye Drags The Sun Publishing Limited to Court

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IN THE HIGH COURT OF LAGOS STATE
IN THE IKEJA JUDICIAL DIVISION
HOLDEN AT IKEJA
SUIT NO: ID/ADR/223/15
BETWEEN
SAM OMATSEYE ”¦”¦”¦ CLAIMANT
AND
THE SUN PUBLISHING LIMITED ”¦”¦”¦. DEFENDANT
(Publishers of the Daily Sun)

STATEMENT OF CLAIM
1. The Claimant is the Chairman of The Nation newpaper’s Editorial Board; a graduate of History from University of Ife (now Obafemi Awolowo University), Ile-Ife.

2. The Defendant is the proprietor and publisher of a popular newspaper called Daily Sun which enjoys wide circulation and readership in Nigeria and abroad.

CLAIMANT’S CREDENTIALS
3. The Claimant avers that he is a poet, playwright, novelist, journalist and columnist of many years standing and has distinguished himself in all these fields of human endeavours over the years.

4. The Claimant avers that he has lectured in Metropolitan State College, Denver, University of Colorado and University of Denver in United States of America.

5. The Claimant avers that far back in 1991, he was the first winner of the Gordon N. Fisher Fellowship for Journalist in the Commonwealth by the Southam Foundation based in Toronto, United States of America.

6. The Claimant avers further that he has also won the Alfred Friendly Press Fellowship in United States during which he was a recipient of the Scripps Howards Prize for deadline reporting with the Rocky Mountain News in Denver.

7. The Claimant in addition avers that he is a winner of the Scribes in Excellence Prize for feature writing for the Association of Black Journalists in the United States.

8. The Claimant avers that he is a four-time winner of the Nigeria Merit Award, once in the reporter category and three times as a columnist of the year.

9. The Claimant avers that he also won the informed category of Diamond Award for Media Excellence three times.

10. The Claimant avers that he is a member of the Governing Council, Lagos State University, Ojo and also an Honorary Fellow, Nigeria Academy of Letters, Lagos.

11. The Claimant further avers that as a result of his exceptional career, he has received several awards and commendations from organisations across the nation and beyond and he is recognized as a leading light on Nigeria’s fight against corruption.

LIBEL AGAINST THE CLAIMANT
12. The Claimant further avers that in its Daily Sun Newspaper of Tuesday, 13th October, 2015, the Defendant falsely and maliciously caused to be printed and published the following words of and concerning the Claimant:

“CALL OMATSEYE TO ORDER, KALU TELLS TINUBU”¦.SAYS THE NATION EMBARRASSMENT TO JOURNALISM”

13. The Claimant further avers that at page 7 of Daily Sun Newspaper of Tuesday, 13th October, 2015, the Defendant falsely and maliciously caused to be printed and published the following words of and concerning the Claimant as an elaboration of the above stated headline:

““We wonder how a supposedly seasoned writer and Editorial Board Chair could not distinguish between propaganda and purely professional reportage in his pecuniary bohemianism. This is indeed unprofessionalism demonstrated by rascally Omatseye”

“”¦.In any case, is Omatseye saying that Tinubu, as the publisher of The Nation, determines what the newspaper publishes? If that is the convention in his organization, it is an entirely different case in The Sun and New Telegraph titles, as Kalu has never interfered in the editorial policy and content of the titles in his newspaper establishments.

“In addition, for purposes of argument, even if that was the routine, it is not against the ethics of journalism for publishers to kill stories as expected by Omatseye, who knows full well that Kalu does not meddle in his publications?

“We sympathize with brazen Omatseye on grounds of his not being a trained journalist or even a news reporter so as to understand the distinction between the news reporting and poetry, which incapacitates his knowledge of the rudiments of the calling which all mass communication sophomores know. It is also unfortunate that since Omatseye returned from America and was rehabilitated by a few past and present governors, he has turned himself to a rabid defence dog for his new benefactors”

“It may equally interest Omatseye to know, if his bovine intelligence will allow him, that Kalu and Tinubu enjoy cordial relationship spanning over three decades. It is Omatseye’s intemperate use of language that almost put him in trouble when he scurrilously and irresponsibly attacked Chief Awolowo clan all in his characteristic self-assignation of worming himself to Tinubu for more survivalist packages”¦”

14. The Claimant hereby pleads and shall rely on a copy of the Daily Sun Newspaper containing the libellous materials at the trial of this suit.

NATURAL AND ORDINARY MEANING OF THE DEFAMATORY WORDS
15. The said words in their natural and ordinary meaning (by direct reference and innuendos) meant and were understood to mean that:

(a) The Claimant is a charlatan, an impostor and fake personality.
(b) The Claimant is a dubious person whose stock in trade is sycophancy and dishonesty.
(c) The Claimant is a mudslinging and dangerous personality.
(d) The Claimant is a corrupt and uncivilized person.

16. The Claimant avers that the libellous publication by the Defendant was widely circulated and read by millions of people in the world and particularly in Nigeria where the Claimant has several associates, friends, family and professional colleagues.

17. The Claimant avers that by reason of the publication of the words set out in paragraph 13 above and their import set out in paragraph 14, the Claimant has been seriously injured in his character, credit, reputation and integrity and has been brought to public scandal, odium and contempt and has suffered damages.

PUBLICATION OF THE LIBELOUS MATERIALS BY THE DEFENDANT

18. The Claimant avers that the libellous materials as shown in “the Daily Sun” was published in the ordinary course of business and accordingly offered for sale to the public.

19. The Daily Sun newspaper circulates in Lagos which is within the jurisdiction of this Honourable Court and around the entirety of the Federal Republic of Nigeria and beyond.

20. The Claimant avers that the Defendant has an online platform that enables readers’ access their publications anywhere in the whole world.

21. The Claimant shall contend at the trial that the action of the Defendant was motivated by malice and with intent to undermine and malign the goodwill and popularity enjoyed by the Claimant.

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22. The Claimant avers that the Defendant knows that the libellous publications are untrue, unfounded and cannot be substantiated.

23. The Claimant further avers that immediately after the publication was released, he received numerous telephone calls from professional colleagues, international associates, multinational organisations, relations, friends and religious leaders expressing their utmost disgust and contempt at the Claimant’s alleged disgraceful, unpatriotic and sacrilegious conducts and questioned the integrity of the Claimant.

24. The Claimant avers that the spurious allegations made by the Defendant are untrue and actuated by malice with intent to malign and undermine the Claimant’s reputation.

PARTICULARS OF MALICE
(a) The allegations in the publication are false and untrue.
(b) The Defendant did not conduct any investigation into the truthfulness of the allegations before publishing them.
(c) The Defendant did not offer the Claimant any opportunity to respond to the allegations before publishing them.
(d) By publishing the allegations in a sensational screaming caption, the Defendant evinced the intention to malign the Claimant and drag his reputation in the mud.

25. The Claimant shall rely on the following facts in support of his claim for damages including exemplary damages.

a. The defamatory words were published in a sensational manner.
b. The Defendant knows or ought to have known that the allegations were untrue and totally unfounded.
c. The Defendant has at the time of instituting this action failed to retract the defamatory statements.
d. The court would be asked to infer that the Defendant published the said words:

i. In the knowledge that they were libellous and/or with reckless disregard as to whether or not they were libellous.
ii. In the belief and calculation that they would injure and damage the Claimant’s reputation.
26. The Claimant avers that he has suffered tremendous damage to his reputation and if the Defendant is not restrained, it will further publish injurious articles against the Claimant.
WHEREFORE, the Claimant claims against the Defendant as follows:
1. A DECLARATION that the publication referred to in paragraph 13 of the Statement of Claim is libellous of the Claimant.

2. AN ORDER for the sum of N1,000,000,000.00 (One Billion Naira) only being damages for the words published of and concerning the Claimant which are libellous by direct reference and innuendo contained at page 5 of the New Telegraph of 13th October, 2015 titled ”˜CALL OMATSEYE TO ORDER, KALU TELLS TINUBU”¦SAYS THE NATION MAN EMBARRASSMENT TO JOURNALISM’.

3. AN ORDER of the Honourable Court for a retraction and an unreserved apology by the Defendant for the words published of and concerning the Claimant which are libellous and contained at page 7 of the Daily Sun of 13th October, 2015 titled ”˜CALL OMATSEYE TO OREDR, KALU TELLS TINUBU”¦SAYS THE NATION MAN EMBARRASSMENT TO JOURNALISM’

4. AN ORDER OF PERPETUAL INJUNCTION restraining the Defendant whether by itself, its agents, privies or servants from further publishing or causing to be published any libellous, injurious or defamatory words against the Claimant.

5. FOR SUCH FURTHER ORDER OR OTHER ORDERS as this Honourable court may deem fit to make in the circumstances of this case.
Dated 22nd day of October, 2015.

FESTUS KEYAMO, ESQ.,
UCHENNA B. MONEKE, ESQ.,
CLAIMANT’S COUNSEL,
FESTUS KEYAMO CHAMBERS,
1, FESTUS KEYAMO LANE,
OFF ADEBAYO MOKUOLU, STREET,
OFF GBAGADA EXPRESSWAY,
BEHIND HOTEL NEWCASTLE,
ANTHONY VILLAGE,
LAGOS STATE.
08055028515, 08033371229
festuskeyamochamberslag@yahoo.com

FOR SERVICE ON DEFENDANT

DAILY SUN PUBLISHING LIMITED,
NO. 2, COSCHARIS STREET,
OFF HAPPYHOME AVENUE,
KIRIKIRI INDUSTRIAL LAYOUT,
APAPA,
LAGOS STATE.

FORM 1
(O. 3 r. 3)
FORM OF WRIT OF SUMMONS
IN THE HIGH COURT OF LAGOS STATE
IN THE IKEJA JUDICIAL DIVISION
HOLDEN AT IKEJA
SUIT NO: ID/ADR/223/15
BETWEEN:
SAM OMATSEYE ”¦”¦”¦ CLAIMANT

AND
THE SUN PUBLISHING LIMITED ”¦”¦”¦ DEFENDANT
(Publishers of the Daily Sun)

TO: THE DEFENDANT of No. 2, COSCHARIS STREET, OFF HAPPYHOME AVENUE, KIRIKIRI INDUSTRIAL LAYOUT, APAPA, LAGOS STATE.

LAGOS

HIGH COURT OF LAGOS STATE

in the …………………………….. Judicial Division of………………………………………………….
CLAIMANT

You are hereby commanded that within forty-two days after the service of this Writ on you, inclusive of the day of such service, you do cause an appearance to be entered for you in an action at the Suit

of…………………………………………………………………………………………………………………… and take notice that in default of your so doing the Claimant(s) may proceed therein, and judgment may be given in your absence.
Dated 22nd day of October, 2015.
……………………………….
REGISTRAR

Memorandum to be subscribed on the writ.

N.B. This Writ is to be served within six calendar months from the date thereof, or, if renewed within three calendar months from the date of the last renewal, including the day of such date, and not afterwards.

The defendant may enter appearance personally or by legal practitioner either by handing in the appropriate forms, duly completed, at the Registry of the High Court in which the action is brought or by sending them to the Registrar by registered post.

WHEREOF the Claimant claims against the Defendant as follows:
1. A DECLARATION that the publication referred to in paragraph 13 of the Statement of Claim is libelous of the Claimant.

2. AN ORDER for the sum of N1,000,000,000.00 (One Billion Naira) only being damages for the words published of and concerning the Claimant which are libelous by direct reference and innuendo contained at page 5 of the New Telegraph of 13th October, 2015 titled ”˜CALL OMATSEYE TO ORDER, KALU TELLS TINUBU”¦SAYS THE NATION MAN EMBARRASSMENT TO JOURNALISM’.

3. AN ORDER of the Honourable Court for a retraction and an unreserved apology by the Defendant for the words published of and concerning the Claimant which are libelous and contained at page 7 of the Daily Sun of 13th October, 2015 titled ”˜CALL OMATSEYE TO OREDR, KALU TELLS TINUBU”¦SAYS THE NATION MAN EMBARRASSMENT TO JOURNALISM’

4. AN ORDER OF PERPETUAL INJUNCTION restraining the Defendant whether by itself, its agents, privies or servants from further publishing or causing to be published any libelous, injurious or defamatory words against the Claimant.

5. FOR SUCH FURTHER ORDER OR OTHER ORDERS as this Honourable court may deem fit to make in the circumstances of this case.

This writ was issued by UCHENNA B. MONEKE, ESQ.,. of FESTUS KEYAMO CHAMBERS

Whose address for service is 1, FESTUS KEYAMO LANE, OFF MUKUOLU STREET, BEHIND HOTEL

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