The embattled former leader of the Movement for the Emancipation of the
Niger Delta (MEND) has started singing like a Canary in his detention
cell.
Okah who is
currently being detained in a South African prison over his alleged role
in the October 1, 2010 bombing made some allegations in an affidavit he
submitted to a court on Wednesday. The affidavit was filed in his fresh
application for bail.
The
President, Dr. Goodluck Jonathan and a number of his aides were
prominently mentioned in the 145-paragraph affidavit. For instance, Okah
alleged that he spoke to the President on behalf of Mrs. Diezani Alison
Madueke before she was made the Minister of Petroleum Resources.
Okah also
alleged that his present predicament cannot be divorced from his refusal
to get MEND to retract their claim of responsibility for the
Independence Day bombing. Okah claimed the Government wanted to pin the
occurrence on some specific northern elements. Excerpts:
IN THE SOUTH GAUTENG HIGH COURT, JOHANNESBURG
(REPUBLIC OF SOUTH AFRICA)
CASE NO: A570/10
In the matter between: –
OKAH, HENRY EMOMOTIMI Applicant
And
THE STATE Respondent
FOUNDING AFFIDAVIT
I, the undersiqned,
HENRY EMOMOTIMI OKAH do hereby make oath and state as follows: –
1.
I am an adult male person, the Applicant herein, currently incarcerated
at the Johannesburg Prison, since my arrest on the 2nd of October 2010.
2. The content of this affidavit falls within my own personal knowledge, except
where it is expressly stated otherwise, and are both true and correct”,
3. I am
charged with certain offences in terms of the Protection of
Constitutional Democracy against Terrorist and Related Activities Act,
Act 33 of 2004 (lithe Terrorist Act”). I have further been advised and
reconfirm that the offences referred to in the Terrorist Act are
referred to in Schedule 6 of the Criminal Procedure Act, Act 51 of 1977
and that I am obliged as such to adduce evidence, having been afforded a
reasonable opportunity to do so, that exceptional circumstances exist
which in the interest of justice permit my release on bail.
INTRODUCTION: HISTORICAL CHRONOLOGY
4. I was
arrested on the 2nd of October 2010 and appeared in Court 12 in the
Regional Court, Johannesburg for the first time on the 4th of October
2010.
5. I applied for and was denied bail in a judgment by the learned Regional Court Magistrate H Louw on the 19thof November 2010.
6. ·1
appealed the judgment of the learned Regional Court Magistrate to the
South Gauteng High Court, Johannesburg under appeal case number
CA340/2010. My appeal was heard by His Lordship Hattingh AJ and
dismissed on the in January 2011. A copy of the judgment of the High
Court is annexed hereto as Annexure “HEO 1″.
7. An application was made on my behalf for leave to appeal, to the Supreme·
Court
of Appeal of South Africa, which application was dismissed by the
learned Hattingh AJ on the 11th of June 2011. I attach hereto a copy of
the order dated the 1ih of June 2011 as Annexure “HEO 2″.
8. The
proceedings of the hearing of the application for bail, in the Regional
Court Johannesburg, as well as the transcripts of the record of the
appeal before Hattingh AJ, will be made available to the above
Honourable Court at the hearing of this application.
9. I have
further been advised by my legal representatives that since appeared in
the South Gauteng High Court, Johannesburg on the 31st of January 2012,
the abovementioned Court is therefore seized with this application by
virtue of the provisions of Section 60(1)(b) of the Criminal Procedure
Act, 51 of 1977 and that the above Honourable Court should hear this
application.
NEW FACTS
10. I have
been advised by my legal representatives that should new facts arise,
subsequent to the historical application and appeal referred to
hereinabove, I am entitled to apply to the above Honourable Court to
take any and all of the new facts into consideration together with the
original application and consider whether I should be released on bail.
11. The
trial is set down to commence in the South Gauteng High Court on 1
October 2012 and I am advised that the trial is projected both by the
State and by my legal representatives on a conservative estimate to last
at least 18 months.
12. I have
been furnished with an indictment dated 23 August 2011 under the hand of
Advocate AR Ackermann SC, confirming that the trial will be conducted
in the South Gauteng High Court.
13. In
anticipation of the upcoming trial, I have been furnished with the
content of the police docket containing the statements and evidence
procured by the investigating officer.
14. The
information contained in the police docket was not made available to me
or my previous legal representatives before the previous bail
application and the bail appeal.
15. As I
will demonstrate hereinunder, my allegation set out in my previous
affidavits in support of my bail application before the learned Regional
Court Magistrate wherein I dealt extensively with the weakness and
defects in the State case is now apparent when a proper and detailed
analysis and comparison is made and drawn between the averments made
under oath by the· investigating officer during the previous bail
application and the evidence, or the lack thereof, which is contained in
the police docket.
16. My legal
representative in the bail application presented oral argument to the
learned Regional Court Magistrate and favoured him with heads of
argument in support of his submissions that I should be released on
bail. Thereafter, during the address by counsel for the State, the
learned Regional Court Magistrate indicated to counsel on behalf of the
State that there was no evidential material placed before the Court,
directly linking me with the crimes allegedly committed in Nigeria,
which were set out in the charge sheet. In this regard I beg leave to
refer the Court to pp 301 to 303 of the record. I deem it prudent to
quote some exchanges between the Court and counsel for the State at p
302:-
COURT: That is not evidence.
PROSECUTOR: I also have evidence that the accused had … (intervenes).
COURT: I am going to interrupt you there. There is no evidential material before the
Court. You cannot say mero
motu that you have evidence. You cannot testify, that is not evidence
before this Court, and I will not accept it as such. It is a mere
statement from yourself If you have evidential material by means of a
statement under oath, or evidence that was presented somehow, maybe an
answer from the accused …(intervenes)
PROSECUTOR: Yes.
COURT: Presented to me, but you are arguing that a mere statement from the State’s
side is somehow elevated
to evidence, that is not, it is certainly not. .. But if you are not
going to give me evidential material that links the accused with the
planting of this, I must accept his version, despite the fact that my
impressions upon him in the witness box, which you can allude to …
(intervenes)
PROSECUTOR: Test.
COURT: That is my opinion at this stage.”
17. As a
result of the aforegoing, the State’s legal representative requested
that the matter stand down and thereafter applied to re-open the State’s
case. (at pp 306 to 307). My legal representative opposed the
application, but the Court ruled that the State be given an opportunity
to re-open its case (record, pp 308 to 309).
18. The
State then presented exhibit UN”, a further affidavit by the
investigating officer, Lieutenant Colonel Zeeman, which affidavit was
read into the record at pp 311 to 316 (exhibit UN”, pp 954 to 958).
19. In
response to exhibit UN”, I filed an affidavit in terms of Section 60(11)
of the Criminal Procedure Act, seeking certain information to be
furnished to me to be able to adequately deal with exhibit UN”. In this
regard I refer the Honourable Court to exhibit “P” (pp 959 to 966).
20. The
learned Magistrate thereafter ordered the South African Police Service
to make a mirror copy image of the hard drive of the computer seized
from my residence and all cellular phone hard drives as well as memories
and the affidavits underlying the application for the warrant of my
arrest, the search and seizure order issued by the Magistrate, be
disclosed. I refer to the Court Order at pp 359 to 360 of the record.
21. Despite
the aforegoing, the State failed to comply with the aforesaid Court
Order. My legal representative then furnished the Court with a second
replying affidavit of myself in response to the State’s failure to have
complied with the Court Order (see record, pp 364 to 388, exhibit “Q”,
my second replying affidavit, pp 967 to 993). The learned Magistrate
thereupon held an enquiry as to why the State failed to comply with his
Order and heard the evidence of three witnesses, Zeeman, Mofamadi and
Makusa (record pp 394 to 412).
22. The
learned Magistrate then made a ruling finding that there was an
unreasonable delay caused by the State and ordered the State that the
relevant copies as ordered by him, be presented to my legal team. I
refer to pp 422 to 423.
23. By
virtue of the fact that I was at that stage detained for over a month,
my legal adviser advised me to proceed with my bail application and
presented argument that I be released on bail (see record, p 423, lines
10 to 16).
24. From a
perusal of exhibit “N”, as well as the judgment of the learned
Magistrate and the judgment of the High Court in dismissing my appeal,
both Courts relied heavily on the contents of exhibit “N”. I have been
advised that it is prudent to annex exhibit “N” hereto since it played a
pivotal role in both Courts denying me bail. I attach exhibit “N”
hereto as Annexure “HEO 3″.
25. I have
now been furnished with a copy of the police docket which I have been
advised by my legal representatives contains all the evidential material
which the State intends to use in my trial. I have studied the police
docket and state categorically that exhibit “N” is false and misleading
with regard to various issues contained therein.
26. The
State alleged in Exhibit ‘N’ that prior to the detonation of the two
motor vehicles improvised explosive devices in Abuja, Nigeria on 1
October 2010, two vehicles namely a Honda and a Mazda 626 were purchased
in Lagos, Nigeria, on the instruction of a person complicit in the
crime.
27. The
explosions took place under the supervision of one Chima Orlu a Nigerian
national. It is alleged that Chima Orlu acted on my instructions. The
State has not furnished any evidence to substantiate this allegation in
the police docket.
28. It was
further alleged by the State that Chima Orlu’s telephone records
revealed that he had been in contact with me on numerous occasions
leading up to 1 October 2010. The telephone records contained in the
police docket do not in any way substantiate these allegations made by
the State in exhibit “N”.
29. The
State also alleged that Chima Orlu sent an SMS message to me at
precisely 10h58:59 on 1 October 2010. The SMS was allegedly followed by
another SMS from Chima Orlu at 13h13:01 and again at 13h29:59 the same
day. It is suggested that the replying SMS’s were sent by me to Chima
Orlu at the times given. The police docket does not contain evidence
substantiating these allegations made by the State.
30. The State also alleged that on 1 October 2010 Chima Orlu made a total of
43 voice calls and had sent 27 SMS messages to co-perpetrators and co-conspirators.
The police docket does not contain any evidence substantiating these allegations made by the State.
31. The
State further alleged that Ben Ebere, a Nigerian national who is also
known as Ben Jessy or Justin Malcolm Umejesi assisted Chima Orlu in the
detonation of the said explosions. Ebere had allegedly been in
telephonic and SMS contact with me right up to 29 September 2010. The
police docket does not contain evidence substantiating these allegations
made by the State.
32.
There were allegedly 1 126 calls from me to Ben Ebere during the period
7 August 2010 to 29 September 2010. The telephone records contained in
the police docket do not in any way substantiate these allegations made
by the State.
33.
There were allegedly 59 SMS’s sent from me to Ben Ebere during the
period 1 July 2010 to 28 September 2010. The telephone records contained
in the police docket does not in any way substantiate these allegations
made by the State.
34. Ben Ebere is a wanted person in Nigeria. I attach hereto a newspaper article as Annexure “HEO 4″.
35. Exhibit
UN” stated that Ben Jessy was in Nigeria during the time of the bombing.
There is no evidence contained in the police docket to substantiate
these allegations.
36. A copy of a photo, the original of which will be made available by my legal
representatives at the hearing hereof, of Ben Jessy and President Jacob Zuma is attached hereto as Annexure “HEO 5″.
37. An e-mail was also
allegedly forwarded to me on 1 October 2010 at 16:25 by two people
arrested in Nigeria relating to the bombing which stated:- “Done, tell
them to leave now.”
38. The police docket does not contain evidence substantiating these allegations made by the State.
39. I propose to deal with the allegations surrounding Chima Orlu in more detail hereunder.
40. The
allegations contained above in respect of the alleged cell phone calls
and SMS messages between me and Chima Orlu are not substantiated by my
cell phone records contained in the police docket.
41.
The e-mail from the perpetrators of the bombing of 1 October 2010
purported by the State to be in its possession, simply does not exist in
the police docket, nor does it exist on the computers or cell phones
seized in the search of my residence.
42.
As stated hereinbefore, the learned Magistrate ordered that the State
gave me access to a disc containing the relevant cellphone records
pertaining to the cellphones allegedly confiscated during the search and
seizure of my residence. The relevant disc contains only two records of
cellphones that belong to my wife and/or children. I respectfully state
that no incriminating evidence was retrieved from these records. I
attach the said report pertaining thereto as “HEO _”.
43. I refer
to Annexure “HEO 4″ above, the newspaper article which appeared in a
Nigerian newspaper and in which the public relations official of the
Nigerian Police Force is quoted as having made available photographs of
the two suspected masterminds behind the bomb blasts. It is significant
to note that no information regarding these individuals is provided
other than their names and their photographs.
44. In Annexure “HEO 4″ Ben Jessy is depicted on the photograph on the right hand side and Chima Orlu on the left hand side.
45. I can now categorically state that the allegations contained in exhibit “N” in
particular
are not substantiated by any independent evidence. I therefore
respectfully state that the so-called evidential material relied on by
the learned Regional Court Magistrate and the High Court does not exist.
I therefore respectfully state that the State’s case against me is
extremely weak and it is unlikely that the State will be successful in a
criminal prosecution against me. I respectfully state that had the
Regional Court and the High Court been appraised of the true facts
pertaining to the so-called “evidence” referred to in exhibit “N”, both
Courts in all probability would have granted me bail.
46. For the
aforegoing reasons, I respectfully state that these factors constitute
new facts, which were previously not presented to either the Regional
Court Magistrate or to the High Court and these new facts and
circumstances entitle me to be released on bail on such conditions and
in such amount as the above Honourable Court may deem fit.
47. Although
my trial has been set down for hearing in the above Honourable Court to
commence on the 1st of October 2012, I respectfully state that it is
extremely unlikely that this case will be finalised during the last term
of 2012. A perusal of the police docket clearly indicates that in order
for the State to prove the allegations contained in the charge sheet,
the State will have to call close to 50 witnesses. The list of witnesses
attached to the indictment contains’ almost in its entirety witnesses
who are in Nigeria. I can only imagine that it will be a logistical
nightmare for the State to secure the attendance of all these witnesses
in South Africa, and that delays in this regard will be unavoidable.
Should the matter go on trial, I intend calling in excess of 100
witnesses from Nigeria in defence of my case.
48. I am not
certain as to whether the State will apply to the Trial Court that
certain of the witnesses’ evidence be taken on commission. This in
itself will result in the trial being protracted for a very lengthy
period of time. Moreover, this trial will be extremely costly and I
cannot envisage at this stage whether I will even be able to afford
legal representation for such a lengthy period of time, let alone
whether it would be viable for such a procedure to be followed.
49. I have
been arrested on the 2nd of October 2010 and at the commencement of the
trial, I would have been in custody for two years. I have been advised
that this in itself is also another factor warranting my release on
bail, as the Constitution of the Republic of South Africa provides that
any person accused of having committed a criminal offence must be
afforded the right to a speedy trial. I submit that these factors also
constitute new facts which should be considered by the above Honourable
Court.
50. In order
not to prolix this application unnecessarily, I wish to refer to the
judgment of the High Court on appeal to it in terms of Section 65 of the
Criminal Procedure Act, 51 of 1977. With respect to the learned Judge,
it is clear that he attached a lot of weight to the affidavit by the
investigating officer, Colonel Zeeman (exhibit UN”)(see judgment on
appeal, pp 6 to 8).
51. Although
Section 60(11)(a) provides that I should satisfy the Court that
exceptional circumstances exist which in the interest of justice permit
my release, I respectfully state that the new facts and circumstances
set out hereinbefore cumulatively constitute exceptional circumstances
which warrant my release on bail on such conditions as the above
Honourable Court may deem fit. Legal argument will be addressed to the
above Honourable Court at the hearing of this application in respect of
the aforegoing issues.
52. I deny
the allegations contained in the indictment and will plead not guilty to
the charges proffered against me by the State.
53. In the
indictment it is alleged by the State that I visited Port Harcourt in
Nigeria during February 2010 to carry out certain acts in Nigeria
(indictment, paragraphs 9 to 17).
54. On the
day of the bombing of 1 October 2010, I received a call from Mr Moses
Jituboh, the Head of Personal Security to President Jonathan, who
solicited my assistance and continued cooperation with President
Goodluck Jonathan towards shifting blame for the bombings to the North
of Nigeria.
55. The
State attempts to substantiate this theory with contradictory statements
from its witnesses and detainees held by the Nigerian Government.
56. One of
its witnesses Mr Emmanuel Allison claims his two blackberry phones to
which I sent incrirninatinq SMS’es were destroyed or lost.
57. His
reason for destroying the phone, being threatening text messages he
alleges to have received from “my boys.” It is absurd to destroy a cell
phone on account of harassing or threatening text massage when the sim
card can easily be replaced.
58. Mr
Allison also claims to know nothing about the bombings of 1 October 2010
but his claim of ignorance is disputed by detainee Mr Obi Nwabueze who
asserts that the State witness Mr Emmanuel Allison, in fact coordinated
the bombing of 1 October 2010.
59.
The purpose of my visit to Nigeria between February and March 2010 was
to market a South African manufactured brick making machine to the Niger
Delta Development Corporation (“NDDC”) and the Ministry of Niger Delta.
This product, I believe could drastically reduce building cost in Niger
Delta.
A copy of the relevant documents substantiating the abovementioned is attached hereto marked Annexure “HEO 6″.
60. In order to give the above Honourable Court certain background facts, I wish to allude to the following.
61. The
Niger Delta where I come from, is an impoverished part of Nigeria that
accounts for close to Four Billion Rand of the daily revenue of the
Nigeria Government, yet it can best be described as one big “squatter
camp” due to it being without electricity, running water, proper roads,
schools, hospitals, sewerage etc.
62.
Introducing this brick making machine was my contribution towards
alleviating the suffering of the people of the Niger Delta.
63. During
my visit to Nigeria, I attended a meeting with the Minister for the
Niger Delta, Mr Godsday Orubebe who promised to examine my proposal when
the Government of President Goodluck Jonathan was firmly rooted.
64. Mr Goodluck Jonathan was then the acting president of Nigeria.
65. In Port
Harcourt, I was schedule to meet with the Managing Director of the NDDC,
Mr Chibuzor Ugwoha. This meeting was arranged by Messrs Rogers Nda and
Larry Ogbomo. A copy of an affidavit by Larry Ogbomo confirming same is
attached hereto marked Annexure “HEO 7″.
66. I stayed at the Novotel hotel where I usually stayed whilst visiting Port Harcourt.
67. During
my stay at the Novotel hotel, I was visited by numerous people as is the
usual with me and most of these visitors were seeking some form of
assistance from me.
68. One such
person was Mr Raphael Damfebo who had during 2009 been introduced to me
by Mr Zion Amada whom I had known for many years. Mr Damfebo claimed to
be unemployed and caring for a terminally ill fiancée. Mr Damfebo also
made mention about previously working for a former militia commander
from the Niger Delta who had abandoned him in the pursuit of securing
lucrative contracts from the Nigerian Government.
69. I have
since 2009 assisted Mr Damfebo financially as far as it was possible,
believing him to be jobless and caring for a terminally ill fiancée.
70. Upon my arrival in Port Harcourt, I was informed by Mr Larry Ogbomon that Mr Ugwoha was unavailable for our meeting.
71. I waited
a few days and decided to leave Port Harcourt when Mr Ugwoha had still
not returned and Mr Ogbomon and Mr Nda refused to assume responsibility
for the cost of my stay at the Novotel hotel. I departed Port Harcourt
for Lagos where I spent a few days.
72. The
State attempts, in the police docket, to give the impression that my
relationship with President Goodluck Jonathan is very bad, but the
contrary is true, my relationship with President Goodluck Jonathan is
very good and I have known President Goodluck Jonathan since about 1999
from when he was Deputy Governor of the Bayelsa State.
73. Since December 2009 when he sought my support towards his campaign for presidency of Nigeria, we had kept in constant touch.
74.
President Goodluck Jonathan used his closest advisor Mr Oronto Douglas
or the Minister for Niger Delta Mr Godsday Orubebe to keep in touch with
me.
75.
Mr Oronto Douglas’ numbers are known to me being +2348055077077 and
+2348033003890 while Mr Godsday Orubebe used the numbers +2348037178432
and +2348055296693.
76.
During March 2010, the then acting President Goodluck Jonathan informed
me that he was sending Mr Oronto Douglas to the Republic of South
Africa to discuss certain issues with me. I attach hereto marked
Annexure “HEO 8″ a handwritten note he wrote whilst visiting Republic of
South Africa.
77. Mr Oronto Douglas arrived on 31 March 2010 and departed 1 April 2010.
78. During
my meeting with Mr Douglas, he informed me that the Northern region of
Nigeria was attempting to prevent President Goodluck Jonathan from
becoming the president of Nigeria and required my assistance.
79. During
the evening of 4 April 2010, I received a call from Mr Douglas who
informed me that a certain Ms Diezani Allison-Madueke desperately
required speaking to me and requested him for my phone number.
80. Mr
Douglas explained to me that she required my assistance in persuading
President Goodluck Jonathan to appoint her as Minister for Petroleum.
81. At Mr Oronto Douglas’ prompting, I reluctantly accepted.
82. During
the evening of 4 April 2012 and the morning of 5 April 2010, I received
approximately twenty calls from Ms Madueke explaining that she was
competing for the post of Minister of Petroleum with the now Minister of
Foreign Affairs Mr Odien Ajumogobia and required my assistance to tip
the scales in her favour.
83. Ms
Madueke requested that I put in a good word for her with President
Goodluck Jonathan whom she said had asked to speak to me.
84. At the
time of her first call, President Goodluck Jonathan was busy and she
continuously called or sent text messages to update me on the Mr
Jonathan’s availability.
85. During the calls he used two different telephone numbers.
86. One of
these numbers was +2347034039944, which she informed me was her number
and another, which I did not save, which she had said belonged to her
personal assistant.
87. I finally spoke to President Goodluck Jonathan during the early hours of 5 April 2010.
88. During
the course of our telephone conversation, he informed me that he was
sending Mr Godsday Orubebe the Minister of Niger Delta to get my
response to the meeting with Mr Oronto Douglas and to brief me on other
matters.
89. The last
call I received from Ms Madueke was at 6:41 :35 on 4 April 2010 during
which she thanked me for my contribution in influencing her appointment
as Minister of Petroleum.
90.
Tension between the Muslim North and Christian South in Nigeria has
been running high and I was/am conscious of inflaming an already
volatile
situation still apparent in Nigeria.
91. Mr
Godsday Orubebe informed me that President Goodluck Jonathan was
disturbed about rumours of me routing for General Babangida from the
North and wanted me to place an advert in the Nigerian newspapers in
support of him.
92.
Mr Orubebe further said that President Goodluck Jonathan was upset with
General Babangida for contesting the election and was going to stop
him, one way or another.
93.
They intended to use the Economic and Financial Crimes Commission
(EFCC) to arrest General Babangida on charges relating to an alleged
embezzlement of public funds during his tenure in office if all attempts
to discourage him from participating in the elections failed.
94. Mr
Orubebe also explained to me that the North appeared to have lost
respect for former militia leaders from the Niger Delta that appeared as
illiterate thugs going around ministries in Abuja and making threats in
the bid to secure government contracts. He went on to suggest that
since I still had credibility and commanded the respect of most
fighters, I should appear publicly as the leader of these former
fighters.
95. He
assured me in this meeting that President Goodluck Jonathan was
determined to ensure that political power never returned to the North
which Mr Orubebe described as parasites.
96. To
achieve this, President Goodluck Jonathan would pretend to do only one
term in office and once entrenched, he would insist on a second term.
97. Mr
Orubebe in that meeting said the North had their chance and they put
forward a very ill and ailing candidate for President.
98. Before
his departure, the Minister of Niger Delta asked one of his aides, Mr
Rodney Ambaowei to attend a demonstration of the brick machine I had
previously tried to market to his ministry. This is confirmed in the
documents attached above marked Annexure “HEO 9″
99. Mr Ambaowei and I attended the demonstration at the premises of the company in North Riding, Johannesburg.
100.
Approximately one month after Mr Godsday Orubebe’s departure from the
Republic of South Africa, I received a call from him informing me they
(President Goodluck Jonathan and Mr Orubebe) were sending someone to
discuss confidential issues with me.
101. The person delegated was Mr Abraham Gillow and aide to Mr Godsday Orubebe.
102.
It is usual for the Nigerian Government to send representative to
discuss issues capable of causing them embarrassment, if exposes and
such issues are never discussed over the telephone.
103.
On his arrival, Mr Gillow informed me that the Nigerian Government
wanted me to supply weapons to the Nigerian Military and I replied that I
was not interested.
104. He then asked if I knew where weapons could be purchased in the Republic of South Africa.
105. He explained to me that the Nigerian Government had obtained quotes from
China and former Eastern Block Countries and wished to compare these quotes with the Republic of South Africa.
106. I then proceeded in his presence to call Dave Sheer Firearms.
107. The
telephone call was placed on speaker for his benefit and he heard from a
representative of Dave Sheer Firearms, the conditions attached to
exporting weapons out of the Republic of South Africa.
108. In
hindsight, I believe that Mr Gillow was sent on a mission by President
Goodluck Jonathan to verify rumours making the round in Nigeria that I
was importing weapons to Nigeria.
109.
President Jonathan, I believe was at this point in time plotting my
arrest to prevent my participation in the Nigerian elections.
110. I was
in constant touch with President Goodluck Jonathan through his Ministers
and Advisors until my arrest on 2 October 2010 and at all this time
wrongly believing my relationship with President Goodluck Jonathan IS
good.
111. For instance I spoke at length with Mr Oronto Douglas on 29 and 30 September 2010.
112. Mr Douglas’ telephone number during these calls was +2348055077077.
113. It has
come to my knowledge that Mr Bassey Umoren and others confirmed by the
State as its witnesses have been detained for more than a year without
access to lawyers. Their freedom has been tied to them giving false
testimony against me at any cost during my trial.
114. The
police docket provides no evidence of the construction of compartments
in the motor vehicles utilised in the bombings of 14 March 2010 and 1
October 2010 nor are there any fingerprint or any other evidence from
the recovered motor vehicles to link anyone. I attach hereto marked
Annexures “HEO 9″ and “HEO 10″ an e-mail from Mr Bassey Umoren dated 31
March 2010 requesting me for assistance in setting up a welding business
and an e-mail dated 8 April 2012 thanking me for helping him.
115.
A study of the police docket further reveals the following: The
evidence supplied by the State in the police docket in the form of
photographs of alleged victims of the bombings of 1 October 2010 and 14
March 2010 provides proof of tampering with a possible crime scene by
the Nigerian Authorities.
116.
In order to influence the proceedings against me in South Africa, the
Nigerian Government presented staged photographs showing alleged victims
being in various stages of being undressed.
117. The
bodies in the photographs are intact showing no signs of trauma
associated with a bombing and they appear in underwear in some cases.
118. With
reference to the photographs of alleged victims of the bombing of 1
October 2010 provided by the State in the police docket, great effort
has been made to conceal the identities of the corpses positioned by the
Nigerian Government. The reason for this being is that these
individuals are not victims of any bombing but corpses taken from a
local mortuary for a photo shoot.
119.
The victims have been placed facing downwards to render them
unrecognizable. Those surrounded by the remnants of burnt out motor
vehicles are spotless with no sign of soot or burns even as the tarred
road beneath these bodies appears to be damaged by fire.
120.
The Nigerian government claimed in a statement issued by the
spokesperson for its State Security Services (SSS) that 6 motor vehicles
were purchased for use in the bombings. The State provided 2 documents
which the State claims to be purchase receipts for the motor vehicles
used in the bombings of 1 October 2010. No further receipts of any were
provided.
121. The
purchase receipts provided are clearly printed from the same computer by
two different individuals approximately 35 kilometres apart.
122. There
are no purchasers’ signatures on the purchase receipts and a deliberate
misspelling of my brother’s surname in other to present the impression
that both motor vehicles were purchased by him.
123. In
addition, both documents are dated 17 September 2010 but on one, the
seller also dates it 17 October 2010 which is most likely the month in
which the documents were generated.
124. The State has as at dated hereof, not provided any photographs of the autopsies of alleged victims of the bombings.
125. On
examination of the pathology documentation relating to an alleged victim
of 1 October 2010 reveals inter alia the following: –
125.1. Mr
Bala is reported to have passed away on 1 October 2010, at the Kings
Care Hospital Zn (zone) 4 Abuja. Evidence provided by the State
indicates that Mr Bala’s corpse was transferred to the Maitama General
Hospital Mortuary on the same day of his death, 1 October 2010.
125.2.
This corpse was escorted to the Maitama General Hospital by police
Corporal Akor Emmanuel, though it is not indicated where this police
corporal found this corpse. An order for post mortem examination as is
required by Nigerian law in cases of unnatural death, was served on the
C.M.D (Chief Medical Director) of the Maitama General Hospital Abuja on 6
October 2010, and the post mortem examination
from
evidence provided by the State indicates to have been conducted on 6
October 2010 at the Maitama General Hospital as per the order for post
mortem examination.
125.3. The post mortem
examination of Mr Verty Bala from the report of this examination was
witnessed by a C.S.P. (Chief Superintendent of Police) whose identity is
not indicated.
125.4. On
conclusion of the post mortem examination of Mr Verty Bala, a warrant to
bury was issued on the same day of the autopsy, 6 October 2010. A
warrant to bury indicates the conclusion of post mortem examinations and
all investigation requiring the presence of the corpse.
125.5.
Contradicting the evidence supplied by the State on Mr Verty Bala, is
the Report of Medical Practitioner attached to Mr Bala’s file, which was
stamped by a hospital more than 50 kilometres away from the Maitama
General Hospital where Mr Verty Bala’s corpse is reported to have been
kept since 1 October 2010.
125.6. Mr
Verty Bala’s Report of Medical Practitioner was stamped and signed by a
medical practitioner at the National Hospital, Abuja, 2 days after Mr
Bala’s reported post mortem examination at the Maitama General Hospital,
and possibly released the corpse to the family for burial as per
warrant to bury.
125.7.
The medical practitioner at the National Hospital, Abuja who had access
to Mr Verty Bala’s corpse, describes the corpse 8 days after the death
and 2 days after a post mortem examination as fresh and neatly dressed
with only a 1 mm puncture wound. This, contradicting a police report
which recorded cuts on the body of Mr Bala on 1
October 2010.
125.8.
The Maitama General Hospital and the National Hospital, Abuja are two
entirely different, unaffiliated hospitals approximately 50 kilometres
apart. A doctor in one hospital cannot attend to patients or victims of
another hospital. Such discrepancies apply to all forensic pathology
reports provided by the State for the bombings of 15 March 2010 and 1
October 2010.
126. The police docket states the following in respect of the alleged victims of the
1 October 2010 bombing:-
126.1. All 7
alleged victims were escorted by the same policeman Corporal Akor
Emmanuel to three different hospitals namely the National Hospital
Abuja, Maitama General Hospital and the Asokoro General Hospital, all of
them being remarkable distances apart.
126.2. The
same Corporal Akor Emmanuel is again indicated to have escorted the
corpse of Mr Verty Bala reported not to have died on the scene but at
the Kings Care Hospital Zone 4, Abuja.
126.3.
The same medical practitioner confirmed with a stamp from the National
Hospital Abuja to have examined the bodies from 3 different hospitals
without being in possession of an authorisation to do so.
126.4.
This medical practitioner claimed to have conducted investigations and
determined the cause of death of all victims, days after the post mortem
examinations and the issuing of the warrants to bury.
126.5. The post mortem
reports are not signed by the pathologists who conducted the autopsy,
most probably an indication that the pathologists at the Maitama General
Hospital, Asokoro General Hospital and the National Hospital Abuja
refused to be co-opted. These post mortem examinations may in fact never
have taken
place.
126.6.
In all 7 post mortem examinations of alleged victims of the 1 October
2010 bombing, the same C.S.P. (Chief Superintendent of Police) is a
witness even though some autopsies were indicated to have been conducted
the same day in three different hospitals approximately 60 kilometres
apart.
126.7. Autopsies in Nigerian Government hospitals are conducted within normal working hours between 9 am and 5 pm.
126.8. No
death certificates were issued for any of the alleged victims of 1
October 2010 in spite of the fact that Nigerian law forbids the burial
or issuing of a warrant to bury, without possession of a death
certificate.
126.9. There
is no evidence that the crime scene was secured for investigators which
the police docket indicates only arrived at the crime scene 2 days
after the bombing of 1 October 2010.
126.10.
The only available explanation for the corpses and evidence
photographed at the scene of bombing is that the bodies were brought to
the scene 2 days later when the investigators arrived on the scene.
126.11. The corpses were turned face down and in different positions with an attempt to conceal their identities.
126.12. The poor picture quality is deliberate and renders it impossible to identify any of the victims.
126.13. With
regards to the alleged victim of the 15 March 2010 bombing the death
certificate was issued 8 months after the alleged death and burial.
126.14. The
Nigerian Coroner’s Act forbids burial in the case of unnatural deaths
without an autopsy, death certificate and warrant to bury.
127. The
issuing of Mr Igbe’s death certificate 8 months after his burial is
preposterous. The death certificate of Mr Igbe an alleged victim of the
bombing of 15 March, 2010, indicates that he was last seen alive by a
witness on the day the death certificate was issued 8 months after his
death.
128. The indictment alleges in the summary of substantial facts that I was a
leader
of the Movement for the Emancipation of the Niger Delta (“MEND”). The
State also levelled certain allegations against MEND. See Summary of
Substantial Facts, paras 2 to 9 – pp 21 to 22 of the indictment.
129. An insight into the workings of MEND will assist in providing a better
understanding
of the bombings of 1 October 2010 and the involvement of President
Goodluck Jonathan’s Government in these bombings. MEND is an amalgam of
independent groups in the Niger Delta region of Nigeria, which groups
struggled to get their land back. This has been going on for
approximately 40 years.
130. It is my belief that President Goodluck Jonathan’s Government working with
a faction of MEND planned and execute the bombings of 14 March 2010 and 1 October 2010.
131. The purpose of the 14 March 2010 bombing in my opinion was to create an
atmosphere of insecurity
in Niger Delta where President Goodluck Jonathan at that time, was
fighting to oust the governor Mr Emmanuel Uduaghan whom President
Goodluck Jonathan intended to replace with his Minister for Niger Delta,
Mr Godsday Orubebe.
132.
The bombing on 1 October 2010 was a platform for the elimination of
political opposition from the North in the form of General Ibrahim
8abangida. The bombings of 1 October 2010 was also intended by the
President Goodluck Jonathan Government to create anti North sentiments
nationwide in order to galvanize support from other sections of Nigeria
against other Northern candidates in the Presidential elections.
133.
Under the arrangement, MEND I believe was not to claim responsibility
for the bombings which the Nigerian government hoped to pin on General
Babangida and other Northern elements.
134.
The claim of responsibility by the central group for a bombing possibly
carried out by the a faction of MEND punctured the plans of President
Goodluck Jonathan to round up his opposition and hold them in custody
until after the elections.
135.
After the bombings of 1 October 2010, the Government of President
Goodluck Jonathan solicited my cooperation in getting the central group
to retract their claim of responsibility. In this regard, I was
contacted by amongst others, Mr Moses Jituboh, a senior police officer
and Head of Personal Security for the Nigerian president and Mr Tony
Uranta, a close ally of President Goodluck Jonathan who caters for
“dirty tasks”.
136. Mr
Jituboh is always with the President and would not dare attempt to
facilitate such an arrangement, without authorization from the
President.
137. Mr
Jituboh called me from his cell with number +234807703333 at 7:20:42 pm
on 1 October 2010. In anticipation of my success in extracting a
retraction, the Nigerian Government began the process of rounding up
opposition politicians. Amongst those arrested was the Campaign manager
of General Babangida, Dr Raymond Dokpesi.
138. My
refusal to cooperate in this scheme resulted in President Goodluck
Jonathan placing a call to President Jacob Zuma during the evening of 1
October 2010, requesting for President Zuma’s personal assistance in
securing my arrest. My noncooperation was interpreted by President
Goodluck Jonathan as support for the Northern politicians. The South
African Government’s direct interference was responsible for securing
search and arrest warrants against me.
139. Mr
Jituboh’s post bombing call to me was widely publicised in the Nigerian
media. If he made these call without the approval of the Nigerian
President to someone whom the Nigerian Government labels a terrorist, Mr
Jituboh would not only have lost his job but would have immediately
been arrested.
140.
Subsequent to Mr Jituboh’s call, I ignored 4 calls from the Minister for
the Niger Delta, Mr Orubebe and 2 calls from an aide to the Minister,
Mr Abraham Gillow. I assumed they were also calling to solicit my
assistance in diverting blame for the bombings of 1 October 2010.
141. During the morning of 2 October 2010, I received two SMS’es from Mr Tony
Uranta.
As earlier stated, Mr Uranata is acknowledged by Nigerians to be
responsible for “dirty tasks” President Goodluck Jonathan would not wish
to be traced to him.
142. The SMS’es were sent from Mr Uranta’s number +2348075407801.
143. The
first of the two SMS’es sent by Mr Uranta at 10h23:05am stated; – “Ask
J.G to withdraw statement.” (J.G being Jomo Gbomo the spokesperson for
MEND).
144. The final SMS sent at 10h28:32 am states; – “The government will blame on
Northern elements.”
145. When
confronted by the Nigerian media about these claims, Mr Uranta’s defence
was that his phone was stolen on the day in question and the thief must
have sent me the SMS’es.
146.
President Jonathan’s earlier exoneration of MEND and me in the bombings
of 1 October 2010 was done with the belief that MEND would retract its
statement paving the way for President Jonathan’s planned persecution of
political opposition. I attached hereto marked Annexure “HEO 11″
several press articles published on the internet in this regard.
147.
President Jonathan’s only concern after the bombings of 1 October 2010
was my unwillingness to assist them in directing blame for the bombings
at opposition candidates from the North of Nigeria.
148. The
embarrassment caused to Mr Goodluck Jonathan by the continued insistence
in its claim of responsibility by MEND provoked President Jonathan’s
relentless pursuit and persecution of me with the assistance of the
South African Government.
149. The
State has made a desperate attempt to construct its fictional case
against me based on its vague knowledge of my itinerary whilst in
Nigeria, my relationship with President Goodluck Jonathan and other
members of the Nigerian Government.
150. There
are daily attacks against oil installations and workers in the Niger
Delta which the Nigerian Government with the assistance of the oil
companies cover-up. The cover-up is necessary to stabilise global oil
prices and increase investor confidence in Nigeria. Oil companies are
unable to hide such attacks only when forced to declare force majeure.
Small attacks are declared to be industrial accident and abductions by
militia groups raising funds for logistics are termed to be random and
rare acts of piracy. I attached hereto marked Annexure “HEO 12″ press
articles published on the internet substantiating same.
151. It is now clear that the State possesses no such evidence and is now forced to rely entirely on untrustworthy statements.
152. The State was very reluctant to bring forward these untrustworthy statements at my previous bail hearing.
153. Amnesty
International, Human Rights Watch and other Non Government
Organisations have clearly documented the ruthlessness, cruelty and
mercilessness of the Nigerian Security Services in the bid to extract
confessions. A copy of their report will be made available to the above
Honourable Court and the hearing of this matter, if requested, and is
not attached hereto in order not to unnecessary attach to many
supporting documents to my affidavit
.
154.
I attach hereto and statement by Obi Nwabueze marked Annexure “HEO 13″
in which it is stated that he has been interrogated by the SSS in
respect of this matter and has been offered freedom and money in
exchange for false testimony against me.
155. I believe that they
are denied access to lawyers sometimes for months until the
interrogators are satisfied with their statement. I myself was a victim
of this process while in custody of the State Security Services of
Nigeria during 2008.
156.
The State’s analysis of items allegedly confiscated in a questionable
search of my home had no connection with the items recovered from the
scene of the bombings or suspects in Nigeria.
157.
In addition no links have been established between me and the cell
phones allegedly recovered by the Nigerian investigators from the scene
of the bombings of 1 October 2010.
158. Mr Timi Alaibe is a
very fraudulent politician in Nigeria known for amassing great wealth
through the theft of public funds. He has been a civil servant all his
life but is worth hundreds of millions of dollars. He based his claims
of my involvement on a gut feeling and was trying to curry favour with
President Goodluck Jonathan ahead of the governorship elections in the
Bayelsa State.
159. Mr Frances Osuwo
(also spelled Osuvwo) through his lawyer complained that he was forced
to sign a statement prepared by Mr Raphael Damfebo and the SSS. Mr Osuwo
is completely illiterate and disputes everything contained in the
statement he signed which was later explained to him by his lawyer.
160. Mr Francis Osuwo was denied access to a lawyer until he signed the statement required by the Nigerian interrogators.
161.
There has been reports in the Media that Mr Osuwo has since passed away
whilst in custody and I attach hereto marked Annexure “HEO 14″ proof
thereof.
162.
In my case, the Nigerian Government attempted to obtain confessions
from one of its informants in South Africa Mr Justin Malcolm Umejesi
(aka Ben Jessy) whom they had declared wanted under the name Ben Ebere.
163. Mr
Justin Malcolm Umejesi (aka Ben Jessy) is well known to the Nigerian
High Commission in Johannesburg and has survived by feeding his handler
Mr Ado at the High Commission with false information for several years.
164. The
High Commission only found out during my previous bail hearing that Mr
Justin Umejesi has had no contact with me since early 2007.
165.
The Nigerian Government had intended to obtain a confession statement
from Mr Umejesi who was to have admitted to seeing me in possession of
items he now believed to be used in the making of bombs.
166.
The revelation at my previous bail hearing that Mr Umejesi had been
scamming the High Commission for years and the High Commission’s later
discovery of a photograph that Mr Umejesi had taken with the South
African President Mr Jacob Zuma making the rounds within the Nigerian
community and have rendered Mr Umejesi useless to the Nigerian
Government.
167.
Contradiction in the statements of the State’s witnesses and detainees
in Nigeria comes from the Nigerian State Security Services and its
ballistics and/or explosives experts.
168. The spokesperson for the State Security Services of Nigeria, Ms Marylyn
Ogar, in a statement to
the media, a copy of which is attached hereto marked Annexure “HEO 15″
and following question and answer session with the Nigerian media, made
the following assertions: –
168.1. Six
motor vehicles were purchased by the alleged perpetrators of the 1
October 2010 bombing for use in the bombing which is contrary to the
statement obtained from one of the detainees in Nigeria who states that
four motor vehicles were purchased for this. The State has supplied 2
purchase receipts in support of the purchase for 2 of the alleged 6
motor vehicles.
168.2.
Ms Marilyn Ogar of the SSS further confirms that her department foiled a
bombing by MEND using two of the six motor vehicles.
168.3.
This bombing according to Ms Marilyn Ogar was planned for 29 September
2010, the SSS claimed to be in possession of the car bombs.
168.4. None of the statements presented by the State supports this claim of such possession by the SSS.
169.
The press release by the SSS highlights measures taken to counter the
threat posed by the warnings of MEND of its intention to detonate the
car bombs at the independence anniversary celebration of 1 October 2010.
170.
Of great importance to the SSS was the use of cell phone jammers which
the SSS claims was credited for preventing the detonation of these bombs
closer to Eagle Square where the celebrations were held.
171. The SSS without a doubt confirms that the bombs were detonated by the use of cellular telephones.
172. There
is no mention in any of the statements provided by the State witnesses
of the use of cellular phones in the detonation of the bombs.
173. The State’s witnesses claim rather that it was timers that were used.
174.
In a report submitted to the Court and produced by the State at my
earlier bail application, the Nigerian bomb experts reported to have
recovered fragments of two cellular phones at the scene of the bombings
of 1 October 2010.
175. These phones were linked to the bombings by the unique alterations peculiar to its use for detonating bombs.
176. Such alterations include multi core cables attached to both phones.
177. The
Nigerian bomb expert confirms an earlier claim made by Ms Marilyn Ogar
of the State Security Services that cell phones were indeed used in
detonating the bombs.
178. No timers or fragments of such were recovered at the bomb scene or present in the states docket.
179.
Contradicting the findings of the Nigerian experts are the statements
of State witnesses and Nigerian detainees who refer to a timer and there
is no mention of the use of cell phones.
180.
The statement of Warrant Officer L.A Smith of the Forensic Science
Laboratory of the S.A.P.S, infers in paragraph 4 that the Nigerian
analysis of the scene of the bombings of 1 October 2010, yielded
evidence pointing to the use of nitro-glycerine based explosive used in
the twin bombings.
181. This evidence is at
odds with the statements of its witnesses, the Nigerian detainees and
claims of the State that dynamite was used in the bombings.
182. Dynamite available in Nigeria is originally imported for commercial use in solid mineral mining and oil exploration.
183. The use
of nitro-glycerine in commercial explosive such as dynamite has been
discontinued for decades due to the unstable nature of nitro-glycerine.
184.
Used in dynamite decades ago, nitro-glycerine was known to “weep” out
of the mixture and cause explosions and death just by transporting this
deadly compound.
185. Modern day dynamite has its active agent, ammonium nitrate and not nitroglycerine.
186.
Upon the recent arrest in Nigeria of Mr Segun Ilorri, Mr Nonso Nwosu (A
banker) and Mr Chima Orlu, the spokesperson for the State Security
Services of Nigeria, Ms Marilyn Ogar described the contributions of the
below mentioned individuals in the bombings of 15 March 2010 and 1
October 2010 as follows: –
SEGUN ILORI
186.1. Arms
trafficker who supplied weapons used in the bombing of 1 October 2010.
Mr Ilori was also alleged to have supplied other components of the bombs
of 1 October 2010. The components were never named. The allegations
against Mr Ilori are outrageous as there has never been any mention of
firearms in either bombing of 15 March or 1 October 2010.
186.2. There
is no mention in any of the witness statements of any activity relating
to any bombing which Mr IIori was engaged in.
186.3. The
State desires to tie Mr IIori to both bombings with the hope that an
innocent SMS sent to him by me during February 2010, be construed as
part of a conspiracy to commit a horrendous crime.
186.4. This
SMS which sought Mr IIori’s assistance in paying monies to certain
accounts was provided to the Nigerian authorities by the SAPS.
186.5. The monies disbursed by Mr IIori were to the accounts of individuals who had requested financial assistance.
186.6. One such individual, Mrs. Beatrice Inaku is a widow who I have supported since the death of her husband.
186.7. Her child resides in England and sent an email to me during or about this time expressing her gratitude for my support.
186.8. I attached hereto marked Annexure “HEO 16″ e-mails substantiating the abovementioned.
MR CHIMA ORLU
186.9. Is alleged to have built the bombs of 1 October 2010 and transported same to Abuja.
186.10.
This claim contradicts previous statements by State witnesses Mr
Emmanuel Allison and detainee Mr Obi Nwabueze and the SSS who were all
in agreement that Mr Obi Nwabueze transported both motor vehicles to
Abuja.
MR NONSO NWOSU
186.11. He is alleged to have coordinated the movement of funds utilised in the bombings of 15 March 2010 and 1 October 2010.
186.12.
This allegation against Mr Nwosu was based on a SMS as this claim is at
odds with the earlier report made by the SSS and investigating officer
in Nigeria, in which Mr Abdul Abubakar named my brother Charles Okah as
the financier of the bombings of 1 October 2010.
187.
A list of people that purportedly died as a result of the bombing, did
not include one Tahir Hassan Zakari Biu, copies of the contact details
of the victims of the October bomb blast and the High Court of South
Africa Indictment dated 23 August 2011.
188. It was
reported in the media that Tahir’s Hassan Zakari Biu family was
compensated by the Nigerian government in a widely publicised manner,
for his death as a result of the bombing.
189. I
attached hereto as Annexure “HEO 17″ an article by the Daily Champion
dated 3 February 2011 and an article by Sahara reporters dated 26
December 2011 and marked “HEO 18″ confirming same.
190. I repeat what I have already stated in my original bail application, namely that: –
190.1. There was no likelihood that my release on bail will endanger the public safety or that of any particular individual;
190.2.
I have no history of violent behaviour and do not have any disposition
to commit offences referred to in Schedule 1 of the Criminal Procedure
Act whilst released on bail. I hold no grudge against anyone either;
190.3. I submitted that there is no likelihood that I will attempt to evade my trial;
190.4. I submitted that this is evident from my conduct since the inception of the investigation;
190.5. I have not supplied any false information nor have I supplied any false information for purpose of this application;
190.6. I
undertake to attend court faithful on each and every occasion to which
the case might be postponed, I have no intention to live the life of a
fugitive.
191. The State replied on the abovementioned as follows: –
191.1. The State said that there was a likelihood that if I will be released on bail I will attempt to evade the trial;
191.2. The State stated that I am extremely wealthy and well connected. Thus I am in the financial position to disappear;
191.3. The State stated that in my own handwriting I attested to previously having attempted and, or having bribed officials;
191.4. I previously attempted to evade justice in Nigeria and was later arrested in Angola and deported back to Nigeria;
191.5. Indicative in my diary I can rely on the systems of valuable and influential sources and aids;
191.6. The
State stated that the local investigation into the current charges
preferred against me is largely reliant on assistance from the Nigerian
authorities. As such, a request for mutual and legal assistance will be
submitted to the Nigerian authorities;
191.7. The
State stated that in all likelihood I will attempt or influence or
intimidate witnesses or would conceal or destroy evidence.
192. Since
the investigation and having received copies of the police docket I have
been aware of all the witnesses against me and I have and will not in
any way intimidate or influence such witnesses.
193. I
further refer the above Honourable Court to paragraphs 7 to 11 of my
founding affidavit on pp 582 to 590 of the record which sets out my
personal particulars and background and pray that the above Honourable
Court take same in consideration in considering this bail application.
194. I humbly pray that the above Honourable Court grant my bail application on new facts.
DEPONENT
THUS
SIGNED AND SWORN TO AT ON THIS DAY OF 2012, THE DEPONENT HAVING
ACKNOWLEDGED THAT HE/SHE KNOWS AND UNDERSTANDS THE CONTENTS OF THIS
AFFIDAVIT, THAT IT IS BOTH TRUE AND CORRECT TO THE BEST OF HIS/HER
KNOWLEDGE AND BELIEF, THAT HE/SHE HAS NO OBJECTION TO TAKING THE
PRESCRIBED OATH AND THAT THE PRESCRIBED OATH WILL BE BINDING ON HIS/HER
CONSCIENCE.
First Published in 2012 by The Street Journal
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