THIRD PARTY APPLICATION WITH AFFIDAVIT, APPLIICATION FOR LEAVE IN REPRESENTATIVE ACTION WITH AFFIDAVIT, APPLICATION FOR JOINDER OF A PARTY WITH AFFIDAVIT

THIRD PARTY APPLICATION



IN THE HIGH COURT OF THE FEDERAL CAPITAL TERRITORY, ABUJA
IN THE ABUJA JUDICIAL DIVISION
HOLDEN AT GWAGWALADA

SUIT NO:…………
MOTION NO:…...

BETWEEN:

DR. HENRY OBAMA ………..……………………. PLAINTIFF

AND

  1. MR DARLINGTON OKOYE (AKA OSAM)... DEFENDANTS/APPLICANTS
  2. CITY LINKS TRANSPORT LTD
AND

ABC INSURANCE CO. PLC ……………………………………… THIRD PARTY

MOTION EX PARTE
BROUGHT PURSUANT TO ORDER 10 RULE 19 OF THE HIGH COURT OF THE FCT (CIVIL PROCEDURE) RULES 2004 AND UNDER THE INHERENT JURISDICTION OF THIS HONOURABLE COURT.

TAKE NOTICE that this Honourable Court will be moved on the …… day of ………………. 2012 at the Hour of 9 O’ clock in the forenoon or so soon thereafter as Counsel for the Defendants/Applicants will be heard praying this Court for:

  1. AN ORDER joining ABC Insurance PLC as a third party in this suit
  2. AND FOR SUCH FURTHER ORDERS as this Court may deem fit to make in the circumstances.


DATED THIS …………… DAY OF ………………………………….. 2012.


……………………….
Njoku Sly, Esq.
Counsel to the
Defenadants/Applicants
Whose address for serviceis:
No 15 Okon Street
Wuse Zone 5 Abuja.








AFFIDAVIT



IN THE HIGH COURT OF THE FEDERAL CAPITAL TERRITORY, ABUJA
IN THE ABUJA JUDICIAL DIVISION
HOLDEN AT GWAGWALADA

SUIT NO:…………
MOTION NO:…...

BETWEEN:

DR. HENRY OBAMA ………..……………………. PLAINTIFF

AND

  1. MR DARLINGTON OKOYE (AKA OSAM)... DEFENDANTS/APPLICANTS
  2. CITY LINKS TRANSPORT LTD
AND

ABC INSURANCE CO. PLC ……………………………………… THIRD PARTY

AFFIDAVIT IN SUPPORT OF THE MOTION FOR THIRD PARTY NOTICE

I, Daniel Ikemson, Adult, Male, Christian, and a Nigerian Citizen residing at No. 15 Kuje FCT Abuja do hereby make oath and state as follows:

  1. That I am the Managing Director of the 2nd Defendant/Applicant and by virtue of which I am conversant with the facts of this case.
  2. I have the consent and authority of my employer to depose to this affidavit.
  3. I know as a fact that on the 15 day of July 2000, the 2nd Defendant bought 15 cars and they were insured with the Third party for a comprehensive cover policy, a copy of the insurance policy is attached and marked as Exhibit A.
  4. That on the 10 day of August 2010, the 1st Defendant, a driver of one of the insured vehicles with registration number XL 252 KUJ had a collision with the Plaintiff.
  5. The Third party is to indemnify the 2nd defendant of any liability arising from such accidents as a term in the insurance policy.
  6. It is in the interest of justice that the third party be joined in this suit.
  7. I make this statement in good faith believing its content to be true and correct in accordance with the Oaths Act 2004.


………………
Deponent



Sworn to at the High Court Registry, Gwagwalada

This …………day of ……………………………… 2012

BEFORE ME

_______________________
COMMISSIONER OF OATHS

APPLICATION FOR LEAVE IN REPRESENTATIVE ACTION



IN THE HIGH COURT OF LAGOS STATE
IN THE IKEJA JUDICIAL DIVISION
HOLDEN AT IKEJA

SUIT NO:………..

BETWEEN:

  1. ALHAJI ASMAU OLA
  2. CHIEF DEDE SANYAOLU ….…….. CLAIMANTS/APPLICANTS
    (SUING FOR THEMSELVES AND ON BEHALF OF THE ODOFIN FAMILY)
AND

CHIEF MOGAJI OKECHUKWU ………………… DEFENDANT

MOTION EX PARTE
BROUGHT PURSUANT TO ORDER 13 RULE 12 OF THE HIGH COURT OF LAGOS STATE (CIVIL PROCEDURE) RULES 2004 AND UNDER THE INHERENT JURISDICTION OF THIS HONOURABLE COURT.

TAKE NOTICE that this Honourable Court will be moved on the …… day of ………………. 2012 at the Hour of 9 O’ clock in the forenoon or so soon thereafter as Counsel for the Claimants/Applicants will be heard praying this Court for:

  1. AN ORDER granting leave to the Applicants to sue for themselves and on behalf of the Odofin family of Ikotun Lagos State.
  2. AND FOR SUCH FURTHER ORDERS as this Court may deem fit to make in the circumstances.


DATED THIS …………… DAY OF ………………………………….. 2012.


…………………………..
Bello Adamu Tope Esq.
Counsel to the Claimants/Applicants
Whose address is:
No. 10 Bagaga Street Ikeja Lagos.






AFFIDAVIT



IN THE HIGH COURT OF LAGOS STATE
IN THE IKEJA JUDICIAL DIVISION
HOLDEN AT IKEJA

SUIT NO:………..

BETWEEN:

  1. ALHAJI ASMAU OLA
  2. CHIEF DEDE SANYAOLU ….…….. CLAIMANTS/APPLICANTS
    (SUING FOR THEMSELVES AND ON BEHALF OF THE ODOFIN FAMILY)
AND

CHIEF MOGAJI OKECHUKWU ………………… DEFENDANT

AFFIDAVIT IN SUPPORT OF THE MOTION EX PARTE

I, Alhaji Asmau Ola, Adult, Male, Muslim, Medical Doctor and a Nigerian Citizen of No. 15 Ikotun Lagos do hereby make oath and state as follows:

  1. That I am a member of the Odofin family House of Ikotun Lagos State and by virtue of which I am conversant with the facts deposed to.
  2. I have the authority and consent of members of the Odofin family to depose to this affidavit.
  3. That the 2nd Claimant/Applicant is also a member of the Odofin family of Ikotun Lagos State.
  4. On the 15 day of July 2011, the Odofin family discovered a trespass on its land at 15 Ikotun Road, Ikotun by the Defendant
  5. The Odofin family held a meeting on the 25 day of July 2011 and appointed both the 1st and 2nd Claimants/Applicants to prosecute an action for trespass on its behalf; a copy of the minutes of the meeting is hereby attached and marked as Exhibit A.
  6. The Applicants will be able to prosecute the matter to a logical conclusion if this application is granted.
  7. The Claimants/Applicants are willing to act as the representatives of the Odofin family in the matter.
  8. It is in the interest of justice to grant this application.
  9. I make this statement in good faith believing its contents to be true and correct in accordance with the Oaths Act 2004.


…..……………….
Deponent



Sworn to at the High Court Registry, Ikeja
This …………..day of …………………… 2012

BEFORE ME

_____________________
COMISSIONER OF OATHS

JOINDER OF PARTY APPLICATION



IN THE NATIONAL AND STATE HOUSES OF ASSEMBLY ELECTION PETITION TRIBUNAL
HOLDEN AT DELTA STATE
ELECTION INTO THE SENATE OF THE NATIONAL ASSEMBLY FOR ASABA
NORTHFEDERAL CONSTITUENCY, DELTA STATE.

PETITION NO:…………

BETWEEN:

  1. DR. BROWN UKE .............PETITIONERS/APPLICANTS
  2. HIS PARTY
AND

  1. CHIEF OKAGBUE
  2. INEC ....................................RESPONDENTS
  3. NATIONAL ASSEMBLY
  4. UNITY CONGRESS PARTY ….… (THE PARTY SOUGHT TO BE JOINED ASTHE 4TH RESPONDENT)

MOTION ON NOTICE
BROUGHT PURSUANT TO ORDER … RULE ….. OF THE ELECTION PETITION PRACTICE DIRECTION 2007 AND WITHIN THE INHERENT JURISDICTION OF THIS TRIBUNAL

TAKE NOTICE that this Honourable Tribunal will be moved on the …… day of ………………. 2012 at the Hour of 9 O’ clock in the forenoon or so soon thereafter as Counsel for the Petitioner/Applicant will be heard praying this Tribunal for:

  1. AN ORDER joining UNITY CONGRESS PARTY as the 4th Respondent in this Petition.
  2. AND FOR SUCH FURTHER ORDERS as this Tribunal may deem fit to make in the circumstances.


DATED THIS …………… DAY OF ………………………………….. 2012.


__________________
Bello Adamu Tope Esq.
Counsel to the Claimants/Applicants
Whose address is:
No. 10 Enugu Street
Delta State.







FOR SERVICE ON:

  1. Chief Okagbue
    No. 15 Cent Street Asaba
  2. INEC
    No. 20 Maitama Abuja.
  3. National Assembly
    Three Arms Zone Abuja
  4. Unity Congress Party


AFFIDAVIT



IN THE NATIONAL AND STATE HOUSES OF ASSEMBLY ELECTION PETITION TRIBUNAL
HOLDEN AT DELTA STATE
ELECTION INTO THE SENATE OF THE NATIONAL ASSEMBLY FOR ASABA
NORTHFEDERAL CONSTITUENCY, DELTA STATE.

PETITION NO:…………

BETWEEN:

  1. DR. BROWN UKE .............PETITIONERS/APPLICANTS
  2. HIS PARTY
AND

  1. CHIEF OKAGBUE
  2. INEC ....................................RESPONDENTS
  3. NATIONAL ASSEMBLY
  4. UNITY CONGRESS PARTY ….… (THE PARTY SOUGHT TO BE JOINED ASTHE 4TH RESPONDENT)

AFFIDAVIT IN SUPPORT OF MOTION ON NOTICE

I, Dr. Brown Uke, Adult, Male, Christian, Business man and Citizen of Nigerian hereby make oath and state as follows:

  1. That I am the 1st Petitioner/Applicant in this matter and by virtue of which I am conversant with the facts of this case.
  2. I have the consent and authority of the 2nd Petitioner/Applicant to depose to this affidavit.
  3. The 1st Respondent contested the Senatorial election under the platform of Unity Congress Party and was returned the winner.
  4. That the 4th Respondent need be joined in this petition so that the judgment of the Court will be binding on it.
  5. It is in the interest of justice to grant this application.
  6. I make this statement in good faith believing its contents to be true and correct in accordance with the Oaths Act 2004.


…………….
Deponent



Sworn to at the High Court Registry, Ikeja
This …………..day of …………………… 2012

BEFORE ME

______________________
COMISSIONER OF OATHS