Governor El rufai’s N500m suit against Reno Omokri and Thisday Newspapers

CONCURRENT WRIT OF SUMMONS – IN THE HIGH COURT OF THE FEDERAL CAPITAL TERRITORY – IN THE ABUJA JUDICIAL DIVISION HOLDEN AT ABUJA

SUIT NO.: FCT/HC/CV/ /2020

BETWEEN:
MALLAM NASIR EL – RUFAI, OFR ==================== CLAIMANT

AND

1. MR. RENO OMOKRI
2. THISDAY NEWSPAPERS LIMITED DEFENDANTS

YOU ARE HEREBY COMMANDED to within FOURTEEN (14) days after 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 the Claimant and TAKE NOTICE that in default of your so doing and take notice that in default the Plaintiff may proceed, and judgment may be given in your absence.

TAKE FURTHER NOTICE that parties shall maintain status quo.

MEMORANDUM TO BE SUBSCRIBED ON THE WRIT

ENDORSEMENT OF CLAIM

a. A DECLARATION that the statement made by the 1st Defendant against the person of the Claimant under the banner “El-Rufai’s Email Saying Southern Women Youth Corpers are Seen as Whores” and published by the 2nd Defendant is defamatory and greatly injurious to the reputation of the Claimant.

b. The sum of N500, 000,000 (Five Hundred Million Naira Only) against the Defendants as general damages for injury, embarrassment and distress suffered by the Claimant in respect of the loss of reputation and goodwill as a result of the malicious, unwarranted and defamatory publication against the person of the Claimant as contained in the Sunday 14th June, 2020 online edition of the Defendant’s newspaper publication, ‘thisdaylive.com’; and wide circulation of same defamatory material/content.

c. AN ORDER that the Claimant is deservingly entitled to a written apology from the Defendants, published with same prominence as the offending publications.

d. AN ORDER of perpetual injunction restraining the Defendants from further defaming the reputation of the Claimant and publication of defamatory content against the Claimant.

This writ was issued by A.U. Mustapha, SAN, whose address for service is A. U. MUSTAPHA & CO., Tree House, No. 32, Mediterranean Street, Maitama District, Abuja, for the said Claimant.

CLAIMANT’S STATEMENT OF CLAIM

1. The Claimant is a distinguished Professional Quantity Surveyor by profession, founding Partner of El-Rufai & Partners Limited, a former Chairman of the National Strategic Grains Reserve Silos Contracts Evaluation Panel, a former Director General of the Bureau of Public Enterprises (B.P.E.), a former Honourable Minister of the Federal Capital Territory, Abuja, Former Deputy National Secretary, All Progressive Congress (APC) and the present Governor of Kaduna State. The Claimant pleads and shall rely on letters of appointments and documents with respect to the above-mentioned offices.
2. The Claimant who commands a brilliant academic pedigree holds a First Class Honours degree in Quantity Surveying from Ahmadu Bello University, Zaria, Nigeria, a Master’s Degree in Business Administration, Master’s Degree in Public Administration and a Bachelor of Law (LL.B) degree from the University of London amongst others is a member of many professional organizations amongst them are Fellow, Nigeria Institute of Management, Fellow, Nigeria Institute of Quantity Surveyors (FNIQS).
3. The Claimant also attended various academic and professional programs at Harvard Business School, Harvard Kennedy School of Government, Arthur D. Little School of Management, and the Georgetown University School of Foreign Service all in the USA, a Postgraduate Diploma in Computer Science (1985) and attended several programs on Privatization and Leadership .He established and ran what became a very successful consulting practice, el-Rufai & Partners, between 1982 and 1998 and has held senior positions with two international telecommunications companies, AT&T Network Systems International BV and Motorola.
4. The Claimant is also actively involved in the promotion of public, civic and humanitarian duties to the society in the course of his education and working career and has won many Honours, prizes and distinctions and has been awarded amongst other recognitions; Fellowship of the Yaba College of Technology, the Doctor of Science (Honoris Causa), by the University of Abuja, FCT, Nigeria in 2005 and a national honour of, OFR (Officer of the Order of the Federal Republic of Nigeria) by the Federal Government of Nigeria in 2001.
5. The Claimant has presented over 180 papers on diverse subjects at seminars, conferences and workshops locally and internationally. The claimant is a prolific writer, columnist and the author of the Bestselling book “The Accidental Public Servant”. And in October 2001 he was conferred a national honour, OFR (Officer of the Order of the Federal Republic of Nigeria) by the Federal Government of Nigeria is happily married with children.
6. The 1st Defendant is a former media aide to ex-President Goodluck Jonathan and now a self-styled social critic.
7. The 2nd Defendant is a Limited Liability Company engaged in business as news publishers and publishes its material through the medium called ‘Thisday’ and publishes online as ‘thisdaylive.com’ with circulation all over Nigeria which publication is also read online all over the world and has its Head office at Lagos, Nigeria.
8. The Claimant avers that in the Sunday June 14, 2020 edition of its aforesaid medium, the 1st Defendant maliciously, unlawfully and without any justification wrote defamatory statement against the Claimant under the banner “El-Rufai’s Email Saying Southern Women Youth Corpers are Seen as Whores” and same was published by the 2nd Defendant at page 56 as follows:-

“Ever since I revealed that the Governor of Kaduna state had sent me an email wherein he said that Southern women youth corpers were seen as “whores”, there have been multiple sophisticated attempts to hack my email account. I do not know why anyone will be stupid enough to think that a meticulous record keeper as myself would leave such a sensitive detail in my inbox. For the attention of those who are trying to hack my account, that email is with my lawyers. The email was sent to me on Wednesday the 27th of April, 2011. The reason I chose to expose its existence is that Nasir El-Rufai is scheming to become Nigeria’s President, and in my opinion, and I am sure in the opinion of every right-thinking person, Nigeria cannot afford another Buharesque autocrat who says that Southern women youth corpers are seen (sic) whores. This was the sentiment expressed by extremist Hutus against Tutsis and was key to dehumanising them before, during and after the Rwandan genocide.”

The Defendants continued in their unlawful and malicious defamation of the Claimant in the said publication thus:-

“Look at what is happening in Southern Kaduna. In recent weeks, Southern Kaduna men, women, children and infants were being killed by herdsmen and the Kaduna State Governor has shown that he is more interested in appeasing and of apologising for the suspected perpetrators. The photographs of the victims are just too gruesome. It is just like a déjà vu of Dogo Na Hauwa. If you do not know what happened in Dogo Na Hauwa, in Plateau State, then Google the massacre that occurred there on March 7, 2010. Two years later, when violence erupted again in Plateau, and it looked like it was going to lead to a reoccurrence of Dogo Na Hauwa, then President Jonathan ordered troops to go to Plateau and keep the peace. I still have chills in my spine when I recall Nasir El-Rufai’s response to the attempt by the Nigerian Army to protect Nigerian citizens. On Sunday, July 15, 2012, Nasir El-Rufai said, and I quote, “We will write this for all to read. Anyone, soldier or not that kills the Fulani takes a loan repayable one day no matter how long it takes.” When you take into account the ferocity, and integrity of the Southern massacre killings and the ease at which the killers can raid these communities, with impunity, and sad to say, gravitas, one can’t stop asking if the loan El-Rufai mentioned on July 15, 2012 is being repaid in 2020. And then imagine if this man gets access to power at the centre. How will he treat Southern Nigerians?”

The unjustified, malicious and unwarranted attacks by the Defendants against the Claimant continued in page 9 of the offensive publication thus:-

“We cannot be so concerned about Black Lives Matter and overlook the lives of Southerners, which obviously do not matter to this man and his family. Derek Chauvin had his knee on the neck of George Floyd for 8 minutes and 46 seconds and Floyd died. Does Southern Nigeria think she can survive if Nasir El-Rufai puts his knee on our necks for four years? You better have another think! The man has not hidden his utter contempt for us. It will amount to masochism on the part of the South, to sit idly by and watch as this man schemes his way to the top, despite the many Freudian slips that have exposed the bigotry burning within him and his sons. We are currently under the yoke of a regime that told us publicly and with a straight face that ‘giving land for ranching is better than death’. Do we want to now hand over to the person that will now actualise that? Are we so much in love with death that we will go to the slaughter without resistance? Is Southern Nigeria a conquered territory? Are there no more men in the South that we will just roll on the floor and allow ourselves to be defiled?“

The Defendants not yet done with their ferocious attack went further to magnify their damages in the offensive publication as follows:
“I remember that former President Olusegun Obasanjo once called for a psychiatric test for anyone aspiring to be the President of Nigeria. I am almost sure that if such a test is performed on Nasir El-Rufai, the results will shock Nigeria. And that is not hyperbole.”

9. The Claimant further avers that on the said day, he logged on to the 2nd Defendant’s website as furnished at paragraph 8 above via his Laptop which was and is still in perfect working condition.
10. The Claimant avers that he printed out the said offending publication and other online publications using one of his computer systems, an Intel Pentium (R), Dual Core, 4.00 GB, 32-bit Operating System coupled to the printer HP LaserJet Pro M402dne desktop printer.
11. The Claimant hereby pleads and shall rely on same printout and other printouts at the trial of this Suit as well as the Certificate to the effect that the computer system used was in excellent working condition before, during and after the printing.
12. The 2nd Defendant widely circulated the offending materials referred to in paragraph 8 above as published in the nationally and internationally read medium which was also published online.
13. The Claimant avers that the above publications portrayed him to any right-thinking man and the general public that he is a selfish, power-hungry, self-serving, religious and ethnic bigot, a violent loving person who sponsors violence and mindless death of innocent people of a different religious and ethnic stock to avenge the killings of his fellow Fulani Muslim and ethnic stock, a shameless schemer and mentally deranged person who would go to any length to acquire the position of power.
14. The Claimant further avers that the publications has done irreparable injury and damage to his hard earned reputation by portraying him as being blinded by religious and ethnic bigot so much that he could not keep faith with his sacred oath of office as the Governor of Kaduna State by upholding his constitutional duty to treat all citizens of Kaduna State fairly and impartially without regard to their religious and ethnic stock and to protect the lives and properties of all Kaduna citizens without discrimination.
15. The Claimant further avers that the above publication complained about has direct inference and constitute a serious and scandalous charge against him as a reputable public office holder, professionally qualified Surveyor of repute and accomplishment and the present Governor of Kaduna State who was re-elected for a second term in office in the March 9, 2019, gubernatorial election.
16. The Claimant will rely on the ordinary and natural meaning of the words complained of and contend that the words are defamatory of him. The Claimant will contend that the following conclusions or imputations can reasonably be inferred and drawn from the words published:-

(i) The Claimant is a misogynist who regards Southern Nigerian women Youth Corpers, Southern Nigerian Women with disdain contempt and total disrespect;

(ii) The Claimant looks at Southern Nigerian women with so much scorn that he does not believe in their human and intellectual capacity and entrepreneurship other than cheaply selling their bodies to men;

(iii) The Claimant looks at Southern Nigerian women are harlots and are good for nothing but to be abused to satisfy the lust of men;

(iv) The Claimant is disreputable and cannot be trusted to stand by his words;

(v) The Claimant is dishonest and fraudulent and can go to any length and embark on the most demeaning action to cover up his track including hacking into e-mail accounts of third parties and engaging others to do so on his behalf;

(vi) The Claimant is autocratic and does not listen to the advice but does what pleases his fancy and base sentiments;

(vii) The Clamant is capable of replicating the genocide that happened in Rwanda in Nigeria which was fueled and driven by deep ethnic hatred as the Claimant habours and nursed deep hatred for men and women of Southern Nigeria.

(viii) The Claimant is power hungry and has unbridled lust for acquisition of power and he is scheming in a subterranean way to be the President of Nigeria in 2023.

(ix) The Claimant is selfish, self-centered, and a schemer;

(x) The Claimant is a religious and ethnic bigot who only cares for the protection of the political interest of the people of his Muslim religion and ethnic Fulani stock;

(xi) The passion of the Claimant’s hatred and disdain for people of other religion and ethnic background is so deep and intense that he sponsors and encourages violence, maiming, killing and wanton destruction of the people of Southern Kaduna who are Christian and of different ethnic stock even as the Governor of the State;

(xii) The Claimant is consumed by hatred of people of other religious and ethnic background that he violates and breaches his sacred oath to uphold the constitution and treat all indigenes of Kaduna equally and without discrimination protect their lives and property;

(xiii) The Claimant always appeases his Fulani ethnic stock each time they carried out dastardly attack against Southern Kaduna indigenes rather than holding the attackers responsible and accountable for their brutality;

(xiv) The Claimant does not have the interest of the people of other ethnic and religious stock of Kaduna State at heart because of his religious and ethnic bigotry;

(xv) The Claimant is on a mission to conquer, despoil, subjugate, oppress and suppress Southern Nigerians of their free will and constitutional rights if he becomes Nigeria President;
(xvi) The Claimant is mentally unstable and has psychiatric problem;

(xvii) The Claimant is unpatriotic and unworthy to occupy public office.

17. The Claimant avers contrary to the false, baseless and malicious publication by the Defendants that the Claimant is misogynist, ethnic and religious bigot, aids and abets wanton destruction of lives and property, is autocratic and oppressive, have genocidal tendencies and subjugation of Southern Nigerians and mentally deranged wish to state as follows:-

(i) The Claimant never has any such opinion, impression or sentiment about Southern Nigerian women or any other women;

(ii) The Claimant regards, treat and relate with women (including Southern Nigerian Women) with the highest degree of respect and deep courtesies;

(iii) The Claimant never looked at Southern Nigerian women as whores;

(iv) The Claimant regards, treat and regards Southern Nigerian women and all women with utmost respect;

(v) The Claimant never sent any such e-mail message to the first Defendant or any other person as falsely and maliciously alleged by the Defendants;

(vi) The Claimant has never directly or indirectly engaged anybody to hack into the 1st Defendant’s e-mail for any reason whatsoever;

(vii) The Claimant has absolute confidence in the intellectual, creative and entrepreneurship ability of all women, including Southern Nigerian women;]

(viii) The Claimant is principled, objective and merit driven in his attitude to both men and women and never influenced by ethic or sexual orientation as he has in his cabinet very capable women of both Southern and Northern Nigeria extraction as Commissioners and special Advisers in strategic ministries and government agencies cutting across Ogun, Osun, Oyo, Katsina, Bauchi, and Adamawa States respectively;

(ix) The Claimant is a law abiding peace loving and peaceful person who eschews violence in any form or manner as way of expressing grievances;

(x) The Claimant is deeply religious and devoted Muslim who strongly believes and upholds the sanctity of human life created only by God and can never and does not habour any genocidal tendencies as the life of every human is precious in the eyes of God;

(xi) The Claimant does not have inordinate political ambition but has always been a seasoned technocrat who accidentally got into politics solely driven by his desire to render selfless service that will add value to the lives of the people and society;

(xii) The Claimant does not only detest and abhors violence but has deep rooted belief in the sanctity of every human life without regards to religion, race and ethnic background;

(xiii) This deep conviction has always steered the Claimant to the path of rule of law, respect for law and order in his personal and public life, and a strong resolve to live, rule and uphold his most sacred oath of office which is anchored on the protection of lives and properties of all indigenes of Kaduna State including all the residents without discrimination as to religion, race or ethnic background;

(xiv) To underscore the seriousness to which the Claimant attach to the issue of security of all indigenes of Kaduna State and its residents, the Claimant created a special Ministry of Internal Security and Home Affairs in order to properly monitor, evaluate and coordinate the state government’s response to security challenges in every part of the state;

(xv) The Claimant avers that the issue of security challenges is not isolated to Kaduna State alone but a burning national challenges affecting all parts of the Country but the Northern part of the Country has been particularly hard hit with the Northwest prone to unrelenting banditry attacks of historical proportion;

(xvi) The Claimant is a nationalist to the core and has a track record of running an open government that accommodates all religion and ethnic group right from his day as the Director General of the Bureau of Public Enterprises, Minister of the Federal Capital Territory and currently as the Governor of Kaduna State including non-indigenes of Kaduna State, he has always treated every constituent of the Country fairly and justly as a detribalized Nigerian. This fact is attested to as the Executive Council of Kaduna State from Commissioners to Special Advisers are drawn from , Delta, Kwara, Kogi, Osun, Adamawa, Kastina, Bauchi and Kaduna States respectively;

(xvii) The Claimant has a track record of seeking quality talents and egg heads from all parts of the country without discrimination and gives consideration to only merit with the sole aim of rendering quality service to the people;

(xviii) The Claimant believes and practices the principle of fairness and equity to all the constituents of the Country and has always regarded and treated all Nigerians of both Northern and Southern extraction irrespective of religion with respect and dignity;

(xix) The Claimant has always regarded and accorded Nigerians of Southern Nigerian extraction with the highest degree and respect;

(xx) The Claimant is highly cerebral, lucid and pragmatic and patriotic;

(xxi) The Claimant’s style of governance and transformational leadership has been a source of positive development for the growth of Kaduna State.

18. The Claimant further avers that at all times material to the offensive publications, the Defendants were aware of the falsity of the contents, but nevertheless published and/or caused same to be published out of spite and/or malicious intent.
19. Further or in the alternative, the Claimant avers that the said word complained of were false and were maliciously published.

Particulars of falsity

i) The Claimant never sent any Email to the 1st Defendant referring to Southern Women Youth Corpers as Whores;

ii) The Claimant never directly or indirectly engaged anybody to hack into the email account of the 1st Defendant;

iii) The Claimant is peace loving and abhors violence;

iv) The Claimant does not want a single human life to be lost unjustly for any reason whatsoever as he strongly believes that no cause deserves the sacrifice of human life;

v) The Claimant has being working tirelessly to ensure that he uphold his constitutional oath to protect the lives and property of all indigenes and residents of Kaduna State without discrimination;
vi) The Claimant is always driven by his desire to do good and uplift the lives of every Nigerian, irrespective of their ethnic, religious and cultural background;

vii) The Claimant will neither oppress nor subject any constituent of the Country to any disadvantage or discrimination, including Southern Nigeria whether as a private citizen, public servant, Kaduna state Governor or any other capacity he occupies office of public service including being the President of Nigeria;

viii) The claimant is cerebral and lucid;

ix) The Claimant is not an ethnic or religious bigot as he runs an all-inclusive government including non-indigenes of Kaduna State all from diverse religious and ethnic background;

x) The Claimant does not have inordinate political ambition for the 2023 presidency.

Particulars of Malice

i) In 2010, the 1st Defendant floated the idea and a plan to act as the Claimant’s political consultant under the impression that the Claimant was interested in contesting the 2011 Presidential election as he believes that the Claimant was the best candidate for the office and so the 1st Defendant approached the Claimant to pay for a 2 years accommodation for him in Abuja, but the request was declined;

ii) The Claimant was never interested in contesting the 2011 Presidential election and when the 1st Defendant realized this fact, he quickly switched his “service” to the Goodluck Jonathan camp;

iii) By reason of the two developments stated above, the 1st Defendant took it upon himself to launch spurious attacks against the Claimant with all the venom in him to position himself for appointment as Special Assistant on Media to ex-President Goodluck Jonathan;

iv) The 1st Defendant also felt slighted by the refusal of the Claimant to pay his two years accommodation in Abuja and therefore nursed deep personal hatred and resentment for the Claimant and his family;

v) The 1st Defendant has translated the above twin reasons to launch unrelenting personal attacks on the Claimant in his official and personal life;

vi) The 1st Defendant who has been out of job since the defeat of ex-President Goodluck Jonathan by incumbent President Mohammed Buhari in 2015 continued to launch unwarranted attacks against the Claimant in a desperate bid to be hired by politicians in opposing camps with the Claimant and this paid off when he was hired by Alhaji Atiku Abubakar, the Presidential candidate of the opposition PDP in the run up to the 2019 Presidential election;

vii) When Alhaji Atiku Abubakar lost the 2019 Presidential election to President Mohammed Buhari, the Claimant became jobless again, hence he continued in his attack against the Claimant in order to get another paymaster from the ranks of forces politically opposed to the Claimant who will hire him again for hatchet job of launching unwarranted and unjustified attacks against the Claimant.

viii) The 1st Defendant always employs all the venom of hatred in him to get even with the Claimant and this he wants to achieve by disparaging the Claimant in all conceivable way by cooking up all sorts of unpalatable stories and fictions about the Claimant as far as his imagination can take him.

ix) The pathological hatred the 1st Defendant nursed for the Claimant is further manifested by the pattern of his unrelenting and unjustified attacks against the Claimant as follows: “HOW Amaechi became driver to Buhari, El-Rufai”-Reno Omokri-banner of Nigerian NewsDirect of March 2 2017, “Gov El-Rufai is a Deceitful Man”-Reno Omokri- banner of Kaduna News Online of January, 7 2018, “Nobody in Nigeria Lies Like El-Rufai”-Reno Omokri-Akelicious banner of September 13, 2019, 2023, “El-Rufai using dethroned Emir to push presidential ambition”-Jonathan’s ex-aide, Omokri-Bioreport.net banner of March 15 2020, “What Igbos will face if El-rufai becomes President”- Reno Omokri-PoliticsNigeria banner of April 12, 2020, “The Satanic Trinity Of El-Rufai, His Son, And His Wife”-By Reno Omokri-Banner of Sahara Reporters of April 27, 2020, “Mail saga: El-Rufai should undergo psychiatric test”-Omokri-Quick Banner of News Africa of June 15, 2020, “El-Rufai is a threat to Nigeria’s national security”-Reno-Banner of Vanguard Newspaper of July 10, 2020 and “Both Buhari and El-Rufai are Twin Evils”-Banner of NAIJALOADED of July 10, 2020 respectively. The Claimant hereby pleads the above publications and seeks to rely on them during trial;

x) The 2nd Defendant is tool in the hands of the Claimant’s political detractors and he is also therefore been used by political opponents who harbors deep personal hatred against the Claimant;

xi) Consequent upon the above, the 1st Defendant is determined on maligning and ruining the reputation of the Claimant and exposes his personality to abhorrence, hatred and disdain;

xii) The 1st Defendant in continuation of the above agenda employed the medium of the 2nd Defendant to launch vindictive attacks on the person and reputation of the Claimant.

xiii) Following the said publication, which was designed to lower the reputation and standing of the Claimant politically, socially and professionally, many colleagues and individuals have continued to make enquires about the credibility, honesty, purposefulness and integrity of the Claimant.

20. The publication has injured the reputation of the Claimant whose standing in life requires utmost integrity, honesty and responsibility.
21. The publication has brought the Claimant into odium and contempt and he has suffered distress, embarrassment and humiliation.
22. As result of the publications in 1st Defendant’s news medium, the Claimant’s reputation has been negatively affected. The Claimant has been brought into public scandal, ridicule and contempt among reasonable minded and right thinking ordinary Nigerians.
23. The Claimant further states that at all times material to the offensive publication, the Defendants were aware of the falsity of the content of the publications stated in paragraphs 4 above, but nevertheless published and/or caused same to be published out of spite and/or malicious intent.
24. The Claimant avers that as a direct consequence of the publication of the quoted words above, he has been subjected to incalculable psychological trauma and loss of reputation, which he has laboured for since the inception of his career spanning over a period of 37 years.
25. The Claimant hereby pleads and shall rely on the publication of the 2nd Defendant of 14th of June 2020 and all relevant documents and correspondences.
26. WHEREOF the Claimant claims against the Defendants jointly and severally as follows:-

a) A DECLARATION that the statement made by the 1st Defendant against the person of the Claimant under the banner “El-Rufai’s Email Saying Southern Women Youth Corpers are Seen as Whores” and published by the 2nd Defendant on Sunday, June 14, 2020, is defamatory and greatly injurious to the reputation of the Claimant.

b) The sum of N500,000,000 (Five Hundred Million Naira Only) against the Defendants as general damages for injury, embarrassment and distress suffered by the Claimant in respect of the loss of reputation and goodwill as a result of the malicious, unwarranted and defamatory publication against the person of the Claimant as contained in the Sunday 14th June, 2020 online edition of the Defendant’s newspaper publication, ‘thisdaylive.com’; and wide circulation of same defamatory material/content.

c) AN ORDER that the Claimant is deservingly entitled to a written apology from the Defendants, published with same prominence as the offending publications.

d) AN ORDER of perpetual injunction restraining the Defendants from further defaming the reputation of the Claimant and publication of defamatory content against the Claimant.

Dated this …………….. day of August, 2020.

…………..………………….
A. U. Mustapha, SAN.
O.A. Dada, Esq.
Aboje Ogbu, Esq
Adetayo Adeyemo, Esq.
S.S. Umoru, Esq.
Ossy Ehikioya, Esq.
Sulaiman Salihu, Esq
Asinmi Lukman, Esq
K. D. Mustapha, Esq
(Counsel to the Claimant)
A.U. MUSTAPHA & CO.

No.32, Mediterranean Street,
Maitama District,
Abuja, FCT – Nigeria.
Tel: 08057466902, 08037685666
admin@aumustapha.com
www.aumustapha.com

CLAIMANT’S LIST OF WITNESSES

1. Mallam Nasir El-Rufai, OFR;
2. Alhaji Husaini Adamu Dikko;
3. Mr. Martins Akumazi;
4. Fausat Ibikunle;
5. Mary Adeola Olarerin
6. Any other witnesses that may be deem necessary during the proceeding.

CLAIMANT’S WITNESS STATEMENT ON OATH

I, Mallam Nasir Ahmad El-Rufai, O.F.R., Male, Muslim, Adult, Nigerian citizen of Plot 1213, Birao Street, Behind AP Plaza, Wuse II, FCT, Abuja and the Governor of Kaduna State, do hereby make oath and state as follows:-

1. I am a distinguished Professional Quantity Surveyor by profession, founding Partner of El-Rufai & Partners Limited, a former Chairman of the National Strategic Grains Reserve Silos Contracts Evaluation Panel, a former Director General of the Bureau of Public Enterprises (B.P.E.), a former Honourable Minister of the Federal Capital Territory, Abuja, former Deputy National Secretary All Progressives Congress (APC) a registered political party in Nigeria, and the present Governor of Kaduna State. I rely on letters of appointments and documents with respect to the above-mentioned offices.
2. I am a holder of a First Class degree in Quantity Surveying from Ahmadu Bello University, Zaria, Nigeria, a Master Degree in Business Administration, a Master Degree in Public Administration, a Bachelor of Law (LL.B) Degree from the University of London amongst others. I am a member of many professional organizations amongst them are Fellow, Nigeria Institute of Management, Fellow, Nigeria Institute of Quantity Surveyors (FNIQS).
3. I also attended various academic and professional programs at Harvard Business School, Harvard Kennedy School of Government, Arthur D. Little School of Management, and the Georgetown University School of Foreign Services all in the USA, a Postgraduate Diploma in Computer Science (1985) and attended several programs on Privatization and Leadership . I established and ran what became a very successful consulting practice, el-Rufai & Partners, between 1982 and 1998 and has held senior positions with two international telecommunications companies, AT&T Network Systems International BV and Motorola.
4. I have over the years been actively involved in the promotion of public, civic and humanitarian duties to the society in the course of his education and working career and has won many Honours, prizes and distinctions and has been awarded amongst other recognitions; Fellow of the Yaba College of Technology, the Doctor of Science (Honoris Causa), by the University of Abuja, FCT, Nigeria in 2005 and a national honour of, OFR (Officer of the Order of the Federal Republic of Nigeria) by the Federal Government of Nigeria in 2001.
5. I have presented over 180 papers on diverse subjects at seminars, conferences and workshops locally and internationally. I am a prolific writer, columnist and the author of the bestselling book “The Accidental Public Servant”. And in October 2001, I was conferred a national honour, OFR (Officer of the Order of the Federal Republic of Nigeria) by the Federal Government of Nigeria and happily married with children.
6. The 1st Defendant is a former media aide to ex-President Goodluck Jonathan and now a self-styled social critic.
7. The 2nd Defendant is a Limited Liability Company engaged in business as news publishers and publishes its material through the medium called ‘Thisday’ and publishes online as ‘thisdaylive.com’ with circulation all over Nigeria which publication is also read online all over the world and has its Head office at Lagos, Nigeria.
8. That in the Sunday June 14, 2020 edition of its aforesaid medium, the 1st Defendant maliciously, unlawfully and without any justification wrote defamatory statement against the me under the banner “El-Rufai’s Email Saying Southern Women Youth Corpers are Seen as Whores” and same was published by the 2nd Defendant at page 56 as follows:

“Ever since I revealed that the Governor of Kaduna state had sent me an email wherein he said that Southern women youth corpers were seen as “whores”, there have been multiple sophisticated attempts to hack my email account. I do not know why anyone will be stupid enough to think that a meticulous record keeper as myself would leave such a sensitive detail in my inbox. For the attention of those who are trying to hack my account, that email is with my lawyers. The email was sent to me on Wednesday the 27th of April, 2011. The reason I chose to expose its existence is that Nasir El-Rufai is scheming to become Nigeria’s President, and in my opinion, and I am sure in the opinion of every right-thinking person, Nigeria cannot afford another Buharesque autocrat who says that Southern women youth corpers are seen (sic) whores. This was the sentiment expressed by extremist Hutus against Tutsis and was key to dehumanising them before, during and after the Rwandan genocide.”

The Defendants continued in their unlawful and malicious defamation of my person in the said publication thus:-

“Look at what is happening in Southern Kaduna. In recent weeks, Southern Kaduna men, women, children and infants were being killed by herdsmen and the Kaduna State Governor has shown that he is more interested in appeasing and of apologising for the suspected perpetrators. The photographs of the victims are just too gruesome. It is just like a déjà vu of Dogo Na Hauwa. If you do not know what happened in Dogo Na Hauwa, in Plateau State, then Google the massacre that occurred there on March 7, 2010. Two years later, when violence erupted again in Plateau, and it looked like it was going to lead to a reoccurrence of Dogo Na Hauwa, then President Jonathan ordered troops to go to Plateau and keep the peace. I still have chills in my spine when I recall Nasir El-Rufai’s response to the attempt by the Nigerian Army to protect Nigerian citizens. On Sunday, July 15, 2012, Nasir El-Rufai said, and I quote, “We will write this for all to read. Anyone, soldier or not that kills the Fulani takes a loan repayable one day no matter how long it takes.” When you take into account the ferocity, and integrity of the Southern massacre killings and the ease at which the killers can raid these communities, with impunity, and sad to say, gravitas, one can’t stop asking if the loan El-Rufai mentioned on July 15, 2012 is being repaid in 2020. And then imagine if this man gets access to power at the centre. How will he treat Southern Nigerians?”

The unjustified, malicious and unwarranted attacks by the Defendants against my person continued in page 9 of the offensive publication thus:-

“We cannot be so concerned about Black Lives Matter and overlook the lives of Southerners, which obviously do not matter to this man and his family. Derek Chauvin had his knee on the neck of George Floyd for 8 minutes and 46 seconds and Floyd died. Does Southern Nigeria think she can survive if Nasir El-Rufai puts his knee on our necks for four years? You better have another think! The man has not hidden his utter contempt for us. It will amount to masochism on the part of the South, to sit idly by and watch as this man schemes his way to the top, despite the many Freudian slips that have exposed the bigotry burning within him and his sons. We are currently under the yoke of a regime that told us publicly and with a straight face that ‘giving land for ranching is better than death’. Do we want to now hand over to the person that will now actualise that? Are we so much in love with death that we will go to the slaughter without resistance? Is Southern Nigeria a conquered territory? Are there no more men in the South that we will just roll on the floor and allow ourselves to be defiled?“

The Defendants not yet done with their ferocious attack went further to magnify their damages in the offensive publication as follows:

“I remember that former President Olusegun Obasanjo once called for a psychiatric test for anyone aspiring to be the President of Nigeria. I am almost sure that if such a test is performed on Nasir El-Rufai, the results will shock Nigeria. And that is not hyperbole.”

9. The 2nd Defendant widely circulated the offending materials referred to in paragraph 8 above as published in the nationally and internationally read medium which was also published online.
10. The above publications portrayed my person to any right thinking man and the general public that I am a selfish, power hungry, self-serving, religious and ethnic bigot, a violent loving person who sponsors violence and mindless death of innocent people of a different religious and ethnic stock to avenge the killings of his fellow Fulani Muslim and ethnic stock, a shameless schemer and mentally deranged person who would go to any length to acquire position of power.
11. The publications has done irreparable injury and damage to my hard earned reputation by portraying me as being blinded by religious and ethnic bigot so much that I could not keep faith with my sacred oath of office as the Governor of Kaduna State by upholding my constitutional duty to treat all citizens of Kaduna State fairly and impartially without regard to their religious and ethnic stock and to protect the lives and properties of all Kaduna citizens without discrimination.
12. The above publication complained about has direct inference and constitute a serious and scandalous charge against me as a reputable public office holder, professional Quantity Surveyor of repute and accomplishment and the present Governor of Kaduna State who was re-elected for a second term in office in the March 9, 2019 gubernatorial election.
13. I rely on the ordinary and natural meaning of the words complained of and contend that the words are defamatory of my person.
14. It is my contention that the following conclusions or imputations can reasonably be inferred and drawn from the words published”

(i) I am a misogynist who regards Southern Nigerian women Youth Corpers, Southern Nigerian Women (Southern Nigerian Women) with disdain contempt and total disrespect;

(ii) I look at Southern Nigerian women with so much scorn that I am unable to believe in their human and intellectual capacity and entrepreneurship other than cheaply selling their bodies to men;

(iii) I look at Southern Nigerian women are harlots and are good for nothing but to be abused to satisfy the lust of men;

(iv) I am disreputable and cannot be trusted to stand by my words;

(v) I am a very dishonest and fraudulent person who can go to any length and embark on the most demeaning action to cover up my track including hacking into e-mail accounts of third parties and engaging others to do so on my behalf;

(vi) I am autocratic and do not listen to advice but does what please my fancy and base sentiments;

(vii) I am capable of replicating the genocide that happened in Rwanda in Nigeria which was fueled and driven by deep ethnic hatred as I habours and nursed deep hatred for men and women of Southern Nigeria;

(viii) I am power hungry and has unbridled lust for acquisition of power and scheming in a subterranean way to be the President of Nigeria in 2023;

(ix) I am selfish, self-centered, and a schemer;

(x) I am a religious and ethnic bigot who only cares for the protection of the political interest of the people of my Muslim religion and ethnic Fulani stock;

(xi) My passion and Claimant’s hatred and disdain for people of other religion and ethnic background is so deep and intense that I sponsor and encourages violence, maiming, killing and wanton destruction of the people of Southern Kaduna who are Christian and of different ethnic stock even as the Governor of the State;

(xii) I am consumed by hatred of people of other religious and ethnic background and Southern Nigerian people that I violate and breach my sacred oath to uphold the constitution and treat all indigenes of Kaduna equally and without discrimination protect their lives and property;

(xiii) I always appease my Fulani ethnic stock each time they carried out dastardly attack against Southern Kaduna indigenes rather than holding the attackers responsible and accountable for their brutality;

(xiv) I do not have the interest of the people of other ethnic and religious stock of Kaduna State at heart because of my religious and ethnic bigotry;

(xv) I am on a mission to conquer, despoil, subjugate, oppress and suppress Southern Nigerians of their free will and constitutional rights if I become Nigeria President;

(xvi) I am mentally unstable and has psychiatric problem;

(xvii) I am unpatriotic and unworthy to occupy public office.

15. That contrary to the false, baseless and malicious publication by the Defendants that I am a misogynist, ethnic and religious bigot, aids and abets wanton destruction of lives and property, autocratic and oppressive, have genocidal tendencies and subjugation of Southern Nigerians and mentally deranged, I wish to state as follows:-

(i) I never had any such opinion, impression or sentiment about Southern Nigerian women or any other women;

(ii) I always regard, treat and relate with women (including Southern Nigerian Women) with the highest degree of respect and deep courtesies;

(iii) I never looked at Southern Nigerian women as whores;

(iv) I regard, treat and regards Southern Nigerian women and all women with utmost respect;

(v) I never sent any such e-mail message to the first Defendant or any other person as falsely and maliciously alleged by the Defendants;

(vi) I have never directly or indirectly engaged anybody to hack into the 1st Defendant’s e-mail for any reason whatsoever;

(vii) I have absolute confidence in the intellectual, creative and entrepreneurship ability of all women, including Southern Nigerian women.

(viii) I am principled, objective and merit driven in my attitude to both men and women and never influenced by ethic or sexual orientation and I have in my cabinet very capable women of both Southern and Northern Nigeria extraction as Commissioners and special Advisers in strategic ministries and government agencies cutting across Ogun, Osun, Oyo, Katsina, Bauchi, and Adamawa States respectively;

(ix) I am a law abiding peace loving and peaceful person who eschews violence in any form or manner as a way of expressing grievances.

(x) I am deeply religious and a devoted Muslim who strongly believes and upholds the sanctity of human life created only by God and can never and does not habour any genocidal tendencies as the life of every human is precious in the eyes of God;

(xi) I do not have inordinate political ambition but has always been a seasoned technocrat who accidentally got into politics solely driven by my desire to render selfless service that will add value to the lives of the people and society;

(xii) I do not only detest and abhors violence but has deep rooted belief in the sanctity of every human life without regards to religion, race and ethnic background;

(xiii) This deep conviction has always steered me to the path of rule of law, respect for law and order in my personal and public life, and a strong resolve to live, rule and uphold my most sacred oath of office which is anchored on the protection of lives and properties of all indigenes of Kaduna State including all the residents without discrimination as to religion, race or ethnic background;

(xiv) To underscore the seriousness to which I attach to the issue of security of all indigenes of Kaduna State and its residents, I created a special Ministry of Internal Security and Home Affairs in order to properly monitor, evaluate and coordinate the state government’s response to security challenges in every part of the state;

(xv) The issue of security challenges is not isolated to Kaduna State alone but a burning national challenges affecting all parts of the Country but the Northern part of the Country has been particularly hard hit with the Northwest prone to unrelenting banditry attacks of historical proportion;

(xvi) I am a nationalist to the core and has a track records of running an open government that accommodates all religion and ethnic group right from my days as the Director General of the Bureau of Public Enterprises, Minister of the Federal Capital Territory and currently as the Governor of Kaduna State including non-indigenes of Kaduna State, I have always treated every constituent of the Country fairly and justly as a detribalized Nigerian. This fact is attested to as the Executive Council of Kaduna State from Commissioners to Special Advisers are drawn from Anambra, Delta, Kwara, Kogi, Osun, Adamawa, Bauchi and Kaduna States respectively;

(xvii) I have a track record of seeking quality talents and egg heads from all parts of the country without discrimination and gives consideration to only merit with the sole aim of rendering quality service to the people;

(xviii) I believe and practice the principle of fairness and equity to all the constituents of the Country and have always regarded and treated all Nigerians of both Northern and Southern extraction irrespective of religion with respect and dignity;

(xix) I have always regarded and accorded Nigerians of Southern Nigerian extraction with the highest degree and respect;

(xx) I am highly cerebral, lucid and pragmatic and patriotic;

(xxi) My style of governance and transformational leadership has been a source of positive development for the growth of Kaduna State.

16. That at all times material to the offensive publications, the Defendants were aware of the falsity of the contents, but nevertheless published and/or caused same to be published out of spite and/or malicious intent.
17. Further or in the alternative, I state that the said words complained of were false and were maliciously published.

Particulars of falsity

i) I never sent any Email to the 1st Defendant referring to Southern Women Youth Corpers as Whores;

ii) I never directly or engaged anybody to hack into the email account of the 1st Defendant;

iii) I am a peace loving and abhors violence;
iv) I do not want a single human life to be lost unjustly for any reason whatsoever as I strongly believe that no cause deserves the sacrifice of human life;

v) I have been working tirelessly to ensure that I uphold my constitutional oath to protect the lives and property of all indigenes and residents of Kaduna State without discrimination;

vi) I am always driven by the desire to do good and uplift the lives of every Nigerian, irrespective of their ethnic, religious and cultural background;

vii) I will neither oppress nor subject any constituent of the Country to any disadvantage or discrimination, including Southern Nigeria whether as a private citizen, public servant, Kaduna state Governor or any other capacity I occupy office of public service including being the president of Nigeria;

viii) I am cerebral and lucid;

ix) I am neither an ethnic nor religious bigot as I run an all-inclusive government including non-indigenes of Kaduna State all from diverse religious and ethnic background;

x) I do not have inordinate political ambition for the 2023 presidency.

Particulars of Malice

i) In 2010, the 1st Defendant floated the idea and a plan to act as the my political consultant under the erroneous impression that I was interested in contesting the 2011 Presidential election as he believes that I was the best candidate for the office and so the 1st Defendant approached me to pay for a 2 years accommodation for him in Abuja, but the request was declined;

ii) I was never interested in contesting the 2011 Presidential election and when the 1st Defendant realized this fact, he quickly switched his “service” to the Goodluck Jonathan camp;

iii) By reason of the two developments stated above, the 1st Defendant took it upon himself to launch spurious attack against the me with all the venom in him to position himself for appointment as Senior Special Assistant on Media to ex-President Goodluck Jonathan;

iv) The 1st Defendant also felt slighted by my refusal to pay his two years accommodation in Abuja and therefore nursed deep personal hatred and resentment for me and my family;

v) The 1st Defendant has always seen me as a threat to his political camp and has taken it upon himself to destroy my standing in the society by his unbridled and baseless attacks

vi) The 1st Defendant has translated the above reasons to launch unrelenting personal attacks on me in my official and personal life;

vii) The 1st Defendant who has been out of job since the defeat of ex-President Goodluck Jonathan by incumbent President Mohammed Buhari in 2015 continued to launch unwarranted attacks against me in a desperate bid to be hired by politicians in opposing camps with me and this paid off when he was hired by Alhaji Atiku Abubakar, the Presidential candidate of the opposition PDP in the run up to the 2019 Presidential election;

viii) When Alhaji Atiku Abubakar lost the 2019 Presidential election to President Mohammed Buhari, the 1st Defendant became jobless again, hence he must continue in his attack against me in order to get another paymaster from the ranks of political forces opposed to the me who will hire him again for his dirty hatched job of unwarranted and unjustified attacks against the my person;

ix) The 1st Defendant always employs all the venom of hatred in him to get even with me and this he wants to achieve by disparaging my person in all conceivable way by cooking up all sorts of unpalatable stories and fictions about my person as far as his imagination can take him;

x) The pathological hatred the 1st Defendant nursed for my person is further manifested by the pattern of his unrelenting unjustified attacks against me as captioned as follows: “HOW Amaechi became driver to Buhari, El-Rufai”-Reno Omokri-banner of Nigerian NewsDirect of March 2 2017, “Gov El-Rufai is a Deceitful Man”-Reno Omokri- banner of Kaduna News Online of January, 7 2018, “Nobody in Nigeria Lies Like El-Rufai”-Reno Omokri-Akelicious banner of September 13, 2019, 2023, “El-Rufai using dethroned Emir to push presidential ambition”-Jonathan’s ex-aide, Omokri-Bioreport.net banner of March 15 2020, “What Igbos will face if El-rufai becomes President”- Reno Omokri-PoliticsNigeria banner of April 12, 2020, “The Satanic Trinity Of El-Rufai, His Son, And His Wife”-By Reno Omokri-Banner of Sahara Reporters of April 27, 2020, “Mail saga: El-Rufai should undergo psychiatric test”-Omokri-Quick Banner of News Africa of June 15, 2020, “El-Rufai is a threat to Nigeria’s national security”-Reno-Banner of Vanguard Newspaper of July 10, 2020 and “Both Buhari and El-Rufai are Twin Evils”-Banner of NAIJALOADED of July 10, 2020 respectively. I hereby rely on the above publications;

xi) The 2nd Defendant is tool in the hands of my political detractors and he is also therefore been used by political opponents who harbors deep personal hatred against me;

xii) Consequent upon the above, the 1st Defendant is determined on maligning and ruining my reputation and expose my person to abhorrence, hatred and disdain;

xiii) The 1st Defendant in continuation of the above agenda employed the medium of the 2nd Defendant to launch vindictive attacks on my person and reputation.

18. Following the said publication, which was designed to lower my reputation and standing politically, socially and professionally, many colleagues and individuals have continued to make enquires about my authenticity of my credibility, honesty, purposefulness and integrity.
19. The publication has injured my reputation as my standing in life requires utmost integrity, honesty and responsibility.

i. That on the said days when the publications were made, I logged on to the 2nd Defendant’s website as well the websites where the other online publications were also made as furnished in my statement above via my Laptop which was and is still in perfect working condition.
ii. That I printed out the said offending publications and other online publications using one of my computer systems, an Intel Pentium (R), Dual Core, 4.00 GB, 32-bit Operating System coupled to the printer HP LaserJet Pro M402dne desktop printer.
iii. That I shall rely on same printout and other printouts at the trial of this Suit as well as the Certificate to the effect that the computer system used was in excellent working condition before, during and after the printing.

20. The publication has brought my person into odium and contempt and I have suffered distress, embarrassment and humiliation.
21. As result of the publications in 1st Defendant’s news medium, my reputation has been negatively affected. I have been brought and subjected to public scandal, ridicule and contempt among reasonable minded and right-thinking ordinary Nigerians and all over the world.
22. That at all times material to the offensive publication, the Defendants were aware of the falsity of the content of the publications stated in paragraphs 4 above, but nevertheless published and/or caused same to be published out of spite and/or malicious intent.
23. That as a direct consequence of the publication of the quoted words above, I have been subjected to incalculable psychological trauma and loss of reputation, which I have laboured for since the inception of my career in public and private sector spanning over a period of 37 years.
24. I hereby rely on the publication of the 2nd Defendant of 14th of June 2020 and all relevant documents and correspondences.
25. That I urge this Honourable Court to grant me Judgement as per my Claims contained in the Writ of Summons and Statement of Claim.
26. That I, Mallam Nasir Ahmad El-Rufai, solemnly and sincerely declare that I make this solemn deposition conscientiously in good faith believing contents of same to be true, correct and in accordance with the provisions of the Oaths Act, 2004 Laws of the Federation of Nigeria.

CLAIMANT’S 1ST WITNESS STATEMENT ON OATH

I, Alhaji Husaini Adamu Dikko, Male, Muslim, Nigeria citizen, Quantity Surveyor of 24, Aminu Kano Crescent, Wuse II, Abuja, do hereby make oath and state as follows:

1. That I am a Partner and Executive Chairman in the firm of El-Rufai and Partners and I know the Claimant very well.
2. That I know as a fact that the Claimant is a Chartered Quantity Surveyor, a former policy adviser, a former Director-General of the Bureau of Public Enterprises (B.P.E.), a former Honourable Minister of the Federal Capital Territory, Abuja; an awardee of the National Honour of Officer of the Federal Republic [O.F.R.] and the current Governor of Kaduna State of Nigeria.
3. That I saw and read the 1st Defendant’s statement on ThisDay’s Newspaper publication of Sunday June 14, 2020 with the caption: “El-Rufai’s Email Saying Southern Women Youth Corpers are Seen as Whores” and same was published by the 2nd Defendant at page 56 as follows:-

“Ever since I revealed that the Governor of Kaduna state had sent me an email wherein he said that Southern women youth corpers were seen as “whores”, there have been multiple sophisticated attempts to hack my email account. I do not know why anyone will be stupid enough to think that a meticulous record keeper as myself would leave such a sensitive detail in my inbox. For the attention of those who are trying to hack my account, that email is with my lawyers. The email was sent to me on Wednesday the 27th of April, 2011. The reason I chose to expose its existence is that Nasir El-Rufai is scheming to become Nigeria’s President, and in my opinion, and I am sure in the opinion of every right-thinking person, Nigeria cannot afford another Buharesque autocrat who says that Southern women youth corpers are seen (sic) whores. This was the sentiment expressed by extremist Hutus against Tutsis and was key to dehumanising them before, during and after the Rwandan genocide.”

The Defendants continued in their unlawful and malicious defamation of the Claimant in the said publication thus:

“Look at what is happening in Southern Kaduna. In recent weeks, Southern Kaduna men, women, children and infants were being killed by herdsmen and the Kaduna State Governor has shown that he is more interested in appeasing and of apologising for the suspected perpetrators. The photographs of the victims are just too gruesome. It is just like a déjà vu of Dogo Na Hauwa. If you do not know what happened in Dogo Na Hauwa, in Plateau State, then Google the massacre that occurred there on March 7, 2010. Two years later, when violence erupted again in Plateau, and it looked like it was going to lead to a reoccurrence of Dogo Na Hauwa, then President Jonathan ordered troops to go to Plateau and keep the peace. I still have chills in my spine when I recall Nasir El-Rufai’s response to the attempt by the Nigerian Army to protect Nigerian citizens. On Sunday, July 15, 2012, Nasir El-Rufai said, and I quote, “We will write this for all to read. Anyone, soldier or not that kills the Fulani takes a loan repayable one day no matter how long it takes.” When you take into account the ferocity, and integrity of the Southern massacre killings and the ease at which the killers can raid these communities, with impunity, and sad to say, gravitas, one can’t stop asking if the loan El-Rufai mentioned on July 15, 2012 is being repaid in 2020. And then imagine if this man gets access to power at the centre. How will he treat Southern Nigerians?”

The statement continued in page 9 of the publication thus:
“We cannot be so concerned about Black Lives Matter and overlook the lives of Southerners, which obviously do not matter to this man and his family. Derek Chauvin had his knee on the neck of George Floyd for 8 minutes and 46 seconds and Floyd died. Does Southern Nigeria think she can survive if Nasir El-Rufai puts his knee on our necks for four years? You better have another think! The man has not hidden his utter contempt for us. It will amount to masochism on the part of the South, to sit idly by and watch as this man schemes his way to the top, despite the many Freudian slips that have exposed the bigotry burning within him and his sons. We are currently under the yoke of a regime that told us publicly and with a straight face that ‘giving land for ranching is better than death’. Do we want to now hand over to the person that will now actualise that? Are we so much in love with death that we will go to the slaughter without resistance? Is Southern Nigeria a conquered territory? Are there no more men in the South that we will just roll on the floor and allow ourselves to be defiled?“

The Defendants not yet done with their ferocious attack went further to magnify their damages in the offensive publication as follows:
“I remember that former President Olusegun Obasanjo once called for a psychiatric test for anyone aspiring to be the President of Nigeria. I am almost sure that if such a test is performed on Nasir El-Rufai, the results will shock Nigeria. And that is not hyperbole.”

4. That upon reading the above publication, I could not resist having the impression that the Claimant, whom I had always held in very high esteem as a paragon of virtue and a bastion of morality and public conscience is himself a selfish, power hungry, self-serving, religious and ethnic bigot, a violent loving person who sponsors violence and mindless death of innocent people of a different religious and ethnic stock to avenge the killings of his fellow Fulani Muslim and ethnic stock, a shameless schemer and mentally deranged person who would go to any length to acquire position of power.
5. That, for the sake of proper articulation of my impressions after the publication, I drew the following conclusions about the character of the Claimant:

(i) He a misogynist who regards Southern Nigerian women with disdain contempt and total disrespect.

(ii) He looks at Southern Nigerian women with so much scorn that he is unable to believe in their human and intellectual capacity and entrepreneurship other than cheaply selling their bodies to men.

(iii) He looks at Southern Nigerian women are harlots and are good for nothing but to be abused to satisfy the lust of men

(iv) He is disreputable and cannot be trusted to stand by his words.

(v) He is very dishonest and fraudulent person who can go to any length and embark on the most demeaning action to cover up his track including hacking into e-mail accounts of third parties and engaging others to do so on his behalf.

(vi) He is autocratic and do not listen to advice but does what pleases his fancy and base sentiments.

(vii) He is capable of replicating the genocide that happened in Rwanda in Nigeria which was fueled and driven by deep ethnic hatred as he habours and nursed deep hatred for men and women of Southern Nigeria.

(viii) He is power hungry and has unbridled lust for acquisition of power and scheming in a subterranean way to be the President of Nigeria in 2023.

(ix) He is selfish, self-centered, and a schemer.

(x) He is a religious and ethnic bigot who only cares for the protection of the political interest of the people of his Muslim religion and ethnic Fulani stock.

(xi) His passion, hatred and disdain for people of other religion and ethnic background is so deep and intense that he sponsors and encourages violence, maiming, killing and wanton destruction of the people of Southern Kaduna who are Christian and of different ethnic stock even as the Governor of the State.

(xii) He is consumed by hatred of people of other religious and ethnic background that he violate and breach his sacred oath to uphold the constitution and treat all indigenes of Kaduna equally and without discrimination protect their lives and property.

(xiii) He always appease his Fulani ethnic stock each time they carried out dastardly attack against Southern Kaduna indigenes rather than holding the attackers responsible and accountable for their brutality.

(xiv) He does not have the interest of the people of other ethnic and religious stock of Kaduna State at heart because of his religious and ethnic bigotry.

(xv) He is on a mission to conquer, despoil, subjugate, oppress and suppress Southern Nigerians of their free will and constitutional rights if he becomes Nigeria President.

(xvi) He is mentally unstable and has psychiatric problem.

(xvii) He is unpatriotic and unworthy to occupy public office.

6. That unable to contain my impressions any longer, I was forced to call him for explanations and he explained that the report was not true. He went further to inform me that he was contemplating a legal action against the Defendant in respect of the content of the publication.
7. That I, Alhaji Husaini Adamu Dikko, solemnly and sincerely declare that I make this solemn deposition conscientiously in good faith believing contents of same to be true, correct and in accordance with the provisions of the Oaths Act, 2004 Laws of the Federation of Nigeria.

CLAIMANT’S 2ND WITNESS’ STATEMENT ON OATH

I, Mr. Martins Akumazi, Male, Christian, Nigerian, Head, Project Implementation and Result Delivery, General Hassan Usman Katsina House, Kaduna, Kaduna State, Nigeria, do hereby make oath and state as follows:

1. That I am a Chartered Quantity Surveyor by profession. I studied Quantity Surveying at the Ahmadu Bello University, Zaria, as a Mobil scholar graduating in 1985. Thereafter, I obtained Masters in Business Administration (MBA) from the University of Lagos (1989) and Bachelor of Laws (LLB) also from the University of Lagos (2000).
2. That I also obtained the following professional qualifications over time: Nigeria Institute of Quantity Surveyors, MNIQS (1988), Royal Institution of Chartered Surveyors, MRICS (2000), Barrister-at-Law, BL (2004).
3. I have worked in various organisations including Mobil Producing Nigeria, Lagos; Lagos State Public Works Corporation, Isheri, Lagos (NYSC), Federal Capital Development Authority, FCDA/FCTA, Area 11, Abuja and ASO Savings & Loans Plc, Abuja.
4. That a larger part of my working career has been with the chartered quantity surveying firm of El-Rufai & Partners Ltd in Kaduna, Lagos and Abuja.
5. That I have known the Claimant for 37years.
6. That I first met the Claimant in 1983 while I was studying quantity surveying at the Ahmadu Bello University Zaria. I was not introduced to him by anyone. I had heard about him as being one of the best quantity surveyors.
7. I simply traveled from ABU, Zaria to Kaduna, found the Claimant’s office, went in straight to him, introduced myself and requested to work in his firm, a consortium of Architects, Engineers and Quantity Surveyors, called Environment Seven, at the Investment House, 27 Ali Akilu Road, Kaduna.
8. The only thing the Claimant did was to ask me a few questions about my school and knowledge of quantity surveying course and immediately granted my request.
9. My classmates could not believe it when I returned to Zaria and talked about my successful trip, meeting and interaction with the Claimant.
10. Since then I have associated closely with the Claimant to date. In 1984, as part my second internship for securing my quantity surveying degree from the Ahmadu Bello University, I was opportune to work once more under the Claimant’s direct supervision for a longer period and this time in his own firm of chartered quantity surveyors.
11. That I returned to school in September 1984 and, as providence would have it, the Claimant who was now engaged as a part time lecturer in the Department of Surveying, Ahmadu Bello University became my teacher and taught me two core courses, Professional Practice and Procedures (PPP) and Civil Engineering Construction Technology.
12. I took greater interest in my quantity surveying course because of the Claimant’s extraordinary professional touch to teaching us especially in our final year.
13. That after my NYSC primary assignment with the Lagos State Government in 1986, I secured employment with El-Rufai & Partners, Lagos Office, a firm owned by the Claimant.
14. When in 2003, the Claimant became the Minister of the Federal Capital Territory, the Claimant invited me to join him as his Special Assistant on Projects which I gladly and gratefully did. This position was desperately sought after and the Claimant could have appointed someone else out of the countless highly qualified and 2 competent construction professionals around him of same religion or ethnicity, the Claimant chose me, a Christian southerner.
15. In 2015 when the Claimant was elected as the Executive Governor of Kaduna State, once more he invited me to join his team as his Special Adviser on Projects; notwithstanding the fact that I am a Southern Nigerian Christian and this is not FCT but Kaduna State.
16. The Claimant’s consideration or basis for selecting his team was purely on merit, not religion, not ethnicity. Other than myself, there are currently many Christian southerners in the Claimant’s Kaduna State team, including several women in the State Executive Council.
17. In all the 37years I have known and associated with the Claimant, I never had cause to consider going elsewhere. I became a permanent part of his family and career. I can confidently claim to know the Claimant better than many people around him today – family, friends and associates alike. I personally consider myself more as a family member than a team member.
18. I have observed, over my 37 years with the Claimant that many Christian southerners like me around him, including women, enjoy similar consideration and respect from the Claimant.
19. The Claimant is, to say the least, exceptionally considerate, accommodating, understanding, selfless and nondiscriminatory especially on religious or ethnic grounds. With the Claimant, when it comes to picking a team for his work, merit is the paramount consideration – not religion, not ethnicity. The people who claim or say otherwise either simply do not know the Claimant at all or do so more probably for some other primordial reasons.
20. That I saw and read the 1st Defendant’s statement on ThisDay’s Newspaper publication of Sunday June 14, 2020 with the caption: “El-Rufai’s Email Saying Southern Women Youth Corpers are Seen as Whores” and same was published by the 2nd Defendant at page 56 as follows:- “Ever since I revealed that the Governor of Kaduna state had sent me an email wherein he said that Southern women youth corpers were seen as “whores”, there have been multiple sophisticated attempts to hack my email account. I do not know why anyone will be stupid enough to think that a meticulous record keeper as myself would leave such a sensitive detail in my inbox. For the attention of those who are trying to hack my account, that email is with my lawyers. The email was sent to me on Wednesday the 27th of April, 2011. The reason I chose to expose its existence is that Nasir El-Rufai is scheming to become Nigeria’s President, and in my opinion, and I am sure in the opinion of every right-thinking person, Nigeria cannot afford another Buharesque autocrat who says that Southern women youth corpers are seen (sic) whores. This was the sentiment expressed by extremist Hutus against Tutsis and was key to dehumanising them before, during and after the Rwandan genocide.”

The Defendants continued in their unlawful and malicious defamation of the Claimant in the said publication thus:

“Look at what is happening in Southern Kaduna. In recent weeks, Southern Kaduna men, women, children and infants were being killed by herdsmen and the Kaduna State Governor has shown that he is more interested in appeasing and of apologising for the suspected perpetrators. The photographs of the victims are just too gruesome. It is just like a déjà vu of Dogo Na Hauwa. If you do not know what happened in Dogo Na Hauwa, in Plateau State, then Google the massacre that occurred there on March 7, 2010. Two years later, when violence erupted again in Plateau, and it looked like it was going to lead to a reoccurrence of Dogo Na Hauwa, then President Jonathan ordered troops to go to Plateau and keep the peace. I still have chills in my spine when I recall Nasir El-Rufai’s response to the attempt by the Nigerian Army to protect Nigerian citizens. On Sunday, July 15, 2012, Nasir El-Rufai said, and I quote, “We will write this for all to read. Anyone, soldier or not that kills the Fulani takes a loan repayable one day no matter how long it takes.” When you take into account the ferocity, and integrity of the Southern massacre killings and the ease at which the killers can raid these communities, with impunity, and sad to say, gravitas, one can’t stop asking if the loan El-Rufai mentioned on July 15, 2012 is being repaid in 2020. And then imagine if this man gets access to power at the centre. How will he treat Southern Nigerians?”

The statement continued in page 9 of the publication thus:
“We cannot be so concerned about Black Lives Matter and overlook the lives of Southerners, which obviously do not matter to this man and his family. Derek Chauvin had his knee on the neck of George Floyd for 8 minutes and 46 seconds and Floyd died. Does Southern Nigeria think she can survive if Nasir El-Rufai puts his knee on our necks for four years? You better have another think! The man has not hidden his utter contempt for us. It will amount to masochism on the part of the South, to sit idly by and watch as this man schemes his way to the top, despite the many Freudian slips that have exposed the bigotry burning within him and his sons. We are currently under the yoke of a regime that told us publicly and with a straight face that ‘giving land for ranching is better than death’. Do we want to now hand over to the person that will now actualise that? Are we so much in love with death that we will go to the slaughter without resistance? Is Southern Nigeria a conquered territory? Are there no more men in the South that we will just roll on the floor and allow ourselves to be defiled?“

The Defendants not yet done with their ferocious attack went further to magnify their damages in the offensive publication as follows:
“I remember that former President Olusegun Obasanjo once called for a psychiatric test for anyone aspiring to be the President of Nigeria. I am almost sure that if such a test is performed on Nasir El-Rufai, the results will shock Nigeria. And that is not hyperbole.”

21. That I had to read the above publication about three times just to be sure I had read correctly and that the contents do indeed refer to the Claimant. I could not help but wonder at how fast otherwise upright people summersault nowadays and descend into the abyss, cesspit and miasma of hatred for people of other regions, ethnic bigotry and lust for power one had thought they were immune to.
22. That upon reading the above publication, I could not resist having the impression that the Claimant, whom I had always held in very high esteem as a paragon of virtue and a bastion of morality and public conscience was himself a selfish, power hungry, self-serving, religious and ethnic bigot, a violent loving person who sponsors violence and mindless death of innocent people of a different religious and ethnic stock to avenge the killings of his fellow Fulani Muslim and ethnic stock, a shameless schemer and mentally deranged person who would go to any length to acquire position of power.
23. That, for the sake of proper articulation of my impressions after the publication, I drew the following conclusions about the character of the Claimant:

(i) He a misogynist who regards Southern Nigerian women with disdain contempt and total disrespect.

(ii) He looks at Southern Nigerian women with so much scorn that he is unable to believe in their human and intellectual capacity and entrepreneurship other than cheaply selling their bodies to men.

(iii) He looks at Southern Nigerian women are harlots and are good for nothing but to be abused to satisfy the lust of men
(iv) He is disreputable and cannot be trusted to stand by his words.

(v) He is very dishonest and fraudulent person who can go to any length and embark on the most demeaning action to cover up his track including hacking into e-mail accounts of third parties and engaging others to do so on his behalf.

(vi) He is autocratic and do not listen to advice but does what pleases his fancy and base sentiments.

(vii) He is capable of replicating the genocide that happened in Rwanda in Nigeria which was fueled and driven by deep ethnic hatred as he habours and nursed deep hatred for men and women of Southern Nigeria.

(viii) He is power hungry and has unbridled lust for acquisition of power and scheming in a subterranean way to be the President of Nigeria in 2023.

(ix) He is selfish, self-centered, and a schemer.

(x) He is a religious and ethnic bigot who only cares for the protection of the political interest of the people of his Muslim religion and ethnic Fulani stock.

(xi) His passion, hatred and disdain for people of other religion and ethnic background is so deep and intense that he sponsors and encourages violence, maiming, killing and wanton destruction of the people of Southern Kaduna who are Christian and of different ethnic stock even as the Governor of the State.

(xii) He is consumed by hatred of people of other religious and ethnic background that he violate and breach his sacred oath to uphold the constitution and treat all indigenes of Kaduna equally and without discrimination protect their lives and property.

(xiii) He always appease his Fulani ethnic stock each time they carried out dastardly attack against Southern Kaduna indigenes rather than holding the attackers responsible and accountable for their brutality.

(xiv) He does not have the interest of the people of other ethnic and religious stock of Kaduna State at heart because of his religious and ethnic bigotry.

(xv) He is on a mission to conquer, despoil, subjugate, oppress and suppress Southern Nigerians of their free will and constitutional rights if he becomes Nigeria President.
(xvi) He is mentally unstable and has psychiatric problem.

(xvii) He is unpatriotic and unworthy to occupy public office.

24. That unable to contain my impressions any longer, I was forced to call him for explanations and the Claimant debunked the statement as being untrue. He went further to inform me that he was contemplating a legal action against the Defendant in respect of the content of the publication.
25. That I, Mr. Martins Akumazi,, solemnly and sincerely declare that I make this solemn deposition conscientiously in good faith believing contents of same to be true, correct and in accordance with the provisions of the Oaths Act, 2004 Laws of the Federation of Nigeria.

WITNESS STATEMENT ON OATH OF MRS FAUSAT IBIKUNLE

I, FAUSAT IBIKUNLE ADEBOLA, Female, Muslim, Nigerian Citizen, Public Servant of General Hassan Usman Kastina House, Kaduna State, do hereby make Oath and state as follows that:

1. That I am an indigene of Kwara State, Nigeria.
2. I am a Public Servant appointed as the Commissioner of Urban and Housing Development by his Excellency, Mallam Nasir El-Rufai, the Governor of Kaduna State and the Claimant in this matter.
3. Prior to my appointment as Commissioner, I held the post of General Manager, Kaduna State Urban Planning and Development Agency KASUPDA from October 2016 to July 2019.
4. As a Directorate cadre officer at the Federal Capital Territory Administration (FCTA) from 2005-2016, two years out of the time I spent as Public Servant in the Federal Capital Development Authority (FCTA) Administration were under the leadership of Malam Nasir Ahmad El-rufai as Minister, FCT.
5. Further to the above, the facts deposed to by me in this Witness Statement are based on my personal knowledge of the Claimant.
6. My first encounter with the Claimant was in 1976 when we were both representing our individual secondary schools at a Schools Challenge programme on NTA Kaduna, we remained friends and we later met as students in A.B.U Zaria.
7. That I enjoyed a very good working relationship with the Claimant at FCTA which is always defined by mutual respect despite my gender, subordinate position and ethnic and religious background as the Claimant is only concerned with job delivery and performance.
8. It was a great honor when the Claimant asked if I would accept to join his team despite my ethnic background in making Kaduna great again in 2016.
9. The Claimant is a wonderful, fair and just boss who does not care where you come from as long as you can deliver on the mandate assigned to you.
10. The above pattern of leadership continued when the Claimant was elected as the Governor of Kaduna State in both 2015 and 2019 as he assembled his Team of both male and female from diverse ethnic and religious background across the Country based purely on merit and it is on this basis that I was appointed to the very important Ministry of Urban and Housing Development, as a Commissioner, even though I am not of his ethnic background.
11. The Kaduna State Executive Council, Heads of parastatals and government agencies and Senior Special Advisers are comprised of both male and female of diverse ethnic and religious background from different parts of the Country.
12. I am shocked and confounded to read the allegation against the Claimant by the 1st Defendant which was published by the 2nd Defendant in their Newspaper of 14th June 2020 under the banner: “El-Rufai’s Email Saying Southern Women Youth Corpers are seen as Whores.” and same was published by the 2nd Defendant at page 56 as follows:-

“Ever since I revealed that the Governor of Kaduna state had sent me an email wherein he said that Southern women youth corpers were seen as “whores”, there have been multiple sophisticated attempts to hack my email account. I do not know why anyone will be stupid enough to think that a meticulous record keeper as myself would leave such a sensitive detail in my inbox. For the attention of those who are trying to hack my account, that email is with my lawyers. The email was sent to me on Wednesday the 27th of April, 2011. The reason I chose to expose its existence is that Nasir El-Rufai is scheming to become Nigeria’s President, and in my opinion, and I am sure in the opinion of every right-thinking person, Nigeria cannot afford another Buharesque autocrat who says that Southern women youth corpers are seen (sic) whores. This was the sentiment expressed by extremist Hutus against Tutsis and was key to dehumanising them before, during and after the Rwandan genocide.”

The Defendants continued in their unlawful and malicious defamation of the Claimant in the said publication thus:-

“Look at what is happening in Southern Kaduna. In recent weeks, Southern Kaduna men, women, children and infants were being killed by herdsmen and the Kaduna State Governor has shown that he is more interested in appeasing and of apologising for the suspected perpetrators. The photographs of the victims are just too gruesome. It is just like a déjà vu of Dogo Na Hauwa. If you do not know what happened in Dogo Na Hauwa, in Plateau State, then Google the massacre that occurred there on March 7, 2010. Two years later, when violence erupted again in Plateau, and it looked like it was going to lead to a reoccurrence of Dogo Na Hauwa, then President Jonathan ordered troops to go to Plateau and keep the peace. I still have chills in my spine when I recall Nasir El-Rufai’s response to the attempt by the Nigerian Army to protect Nigerian citizens. On Sunday, July 15, 2012, Nasir El-Rufai said, and I quote, “We will write this for all to read. Anyone, soldier or not that kills the Fulani takes a loan repayable one day no matter how long it takes.” When you take into account the ferocity, and integrity of the Southern massacre killings and the ease at which the killers can raid these communities, with impunity, and sad to say, gravitas, one can’t stop asking if the loan El-Rufai mentioned on July 15, 2012 is being repaid in 2020. And then imagine if this man gets access to power at the centre. How will he treat Southern Nigerians?”

The statement continued in page 9 of the publication thus:-

“We cannot be so concerned about Black Lives Matter and overlook the lives of Southerners, which obviously do not matter to this man and his family. Derek Chauvin had his knee on the neck of George Floyd for 8 minutes and 46 seconds and Floyd died. Does Southern Nigeria think she can survive if Nasir El-Rufai puts his knee on our necks for four years? You better have another think! The man has not hidden his utter contempt for us. It will amount to masochism on the part of the South, to sit idly by and watch as this man schemes his way to the top, despite the many Freudian slips that have exposed the bigotry burning within him and his sons. We are currently under the yoke of a regime that told us publicly and with a straight face that ‘giving land for ranching is better than death’. Do we want to now hand over to the person that will now actualise that? Are we so much in love with death that we will go to the slaughter without resistance? Is Southern Nigeria a conquered territory? Are there no more men in the South that we will just roll on the floor and allow ourselves to be defiled?“

The Defendants not yet done with their ferocious attack went further to magnify their damages in the offensive publication as follows:-

“I remember that former President Olusegun Obasanjo once called for a psychiatric test for anyone aspiring to be the President of Nigeria. I am almost sure that if such a test is performed on Nasir El-Rufai, the results will shock Nigeria. And that is not hyperbole.”

13. Upon reading the above publication, I could not help but wonder at how fast otherwise upright people summersault nowadays and descend into the abyss, cesspit and miasma of hatred for people of other regions, ethnic bigotry and lust for power one had thought they were immune to.
14. Further to paragraph 14 above, I could not resist having the impression that the Claimant, whom I had always held in very high esteem as a paragon of virtue and model of morality and public conscience was himself a selfish, power hungry, self-serving, religious and ethnic bigot, a violent loving person who sponsors violence and mindless death of innocent people of a different religious and ethnic stock to avenge the killings of his fellow Fulani Muslim and ethnic stock, a shameless schemer and mentally deranged person who would go to any length to acquire position of power.
15. My shock and unbelief sterns from the fact that the allegations contained in the said publication are a direct opposite of the character and person of the Claimant I have known over the years.
16. All the allegations made by the 1st Defendant above which was published by the 2nd Defendant concerning the Claimant’s attitude towards Southern Nigeria women Youth Corpers or Southern Nigerian Women and men, people of other religious and ethnic background are false and does not in any way reflect the Character and person of the Claimant.
17. I have always known the Claimant as a peace loving and detribalized person who accommodates all Nigerians of all ethnic and religious background.
18. That in view of the serious allegations levied against the Claimant I was forced to call the Claimant for explanations and he explained that the report was not true but borne out of malic and vindictiveness. He went further to inform me that he was contemplating a legal action against the Defendants in respect of the content of the publication.
19. That I, Fausat Ibikunle Adebola, solemnly and sincerely declare that I make this solemn deposition conscientiously in good faith believing contents of same to be true, correct and in accordance with the provisions of the Oaths Act, 2004 Laws of the Federation of Nigeria.
    …………………….
    DEPONENT
    WITNESS STATEMENT ON OATH OF MARY ADEOLA OLARERIN

I, MARY ADEOLA OLARERIN, Female, Christian, Nigerian Citizen, Public Servant of General Hassan Usman Kastina House, Kaduna State, do hereby make Oath and state as follows that:

1. I am a Public Servant and Special Adviser to his Excellency, Mallam Nasir El-Rufai, the Governor of Kaduna State on Project Management and Monitoring, the Claimant in this matter.
2. I am also the Head of Kaduna State’s Result Delivery Unit.
3. Prior to my present position in Kaduna State, I have worked as an independent consultant for both governmental and non-governmental organization within and outside Nigeria on Project Management, Management Consultancy and Profiling.
4. In addition to heading the Delivery Unit in Kaduna State, I am the founder of Wealthways Consulting Incorporated.
5. Further to the above, the facts deposed to by me in this Witness Statement are based on my personal knowledge of the Claimant.
6. I am a Southern Nigerian Woman specifically from Ibadan, Oyo State, Nigeria.
7. As a Southern Nigerian woman, I meritoriously earns my living under the administration of Governor Nasir Ahmad El-Rufai, whom I have known for many years as one of the most professional and respectful employers that I have ever worked with.
8. That I enjoyed a very good working relationship with the Claimant which is always defined by mutual respect despite my gender, subordinate position and ethnic and religious background as the Claimant is only concerned with job delivery and performance.
9. The Kaduna State Executive Council, Heads of parastatals and government agencies and Senior Special Advisers is comprised of both male and female of diverse ethnic and religious background from different parts of the Country.
10. I was distressed to read the allegation against the Claimant by the 1st Defendant which was published by the 2nd Defendant in their Newspaper of 14th June 2020 under the banner: “El-Rufai’s Email Saying Southern Women Youth Corpers are seen as Whores.” and same was published by the 2nd Defendant at page 56 as follows:-

“Ever since I revealed that the Governor of Kaduna state had sent me an email wherein he said that Southern women youth corpers were seen as “whores”, there have been multiple sophisticated attempts to hack my email account. I do not know why anyone will be stupid enough to think that a meticulous record keeper as myself would leave such a sensitive detail in my inbox. For the attention of those who are trying to hack my account, that email is with my lawyers. The email was sent to me on Wednesday the 27th of April, 2011. The reason I chose to expose its existence is that Nasir El-Rufai is scheming to become Nigeria’s President, and in my opinion, and I am sure in the opinion of every right-thinking person, Nigeria cannot afford another Buharesque autocrat who says that Southern women youth corpers are seen (sic) whores. This was the sentiment expressed by extremist Hutus against Tutsis and was key to dehumanising them before, during and after the Rwandan genocide.”

The Defendants continued in their unlawful and malicious defamation of the Claimant in the said publication thus:-

“Look at what is happening in Southern Kaduna. In recent weeks, Southern Kaduna men, women, children and infants were being killed by herdsmen and the Kaduna State Governor has shown that he is more interested in appeasing and of apologising for the suspected perpetrators. The photographs of the victims are just too gruesome. It is just like a déjà vu of Dogo Na Hauwa. If you do not know what happened in Dogo Na Hauwa, in Plateau State, then Google the massacre that occurred there on March 7, 2010. Two years later, when violence erupted again in Plateau, and it looked like it was going to lead to a reoccurrence of Dogo Na Hauwa, then President Jonathan ordered troops to go to Plateau and keep the peace. I still have chills in my spine when I recall Nasir El-Rufai’s response to the attempt by the Nigerian Army to protect Nigerian citizens. On Sunday, July 15, 2012, Nasir El-Rufai said, and I quote, “We will write this for all to read. Anyone, soldier or not that kills the Fulani takes a loan repayable one day no matter how long it takes.” When you take into account the ferocity, and integrity of the Southern massacre killings and the ease at which the killers can raid these communities, with impunity, and sad to say, gravitas, one can’t stop asking if the loan El-Rufai mentioned on July 15, 2012 is being repaid in 2020. And then imagine if this man gets access to power at the centre. How will he treat Southern Nigerians?”

The statement continued in page 9 of the publication thus:-

“We cannot be so concerned about Black Lives Matter and overlook the lives of Southerners, which obviously do not matter to this man and his family. Derek Chauvin had his knee on the neck of George Floyd for 8 minutes and 46 seconds and Floyd died. Does Southern Nigeria think she can survive if Nasir El-Rufai puts his knee on our necks for four years? You better have another think! The man has not hidden his utter contempt for us. It will amount to masochism on the part of the South, to sit idly by and watch as this man schemes his way to the top, despite the many Freudian slips that have exposed the bigotry burning within him and his sons. We are currently under the yoke of a regime that told us publicly and with a straight face that ‘giving land for ranching is better than death’. Do we want to now hand over to the person that will now actualise that? Are we so much in love with death that we will go to the slaughter without resistance? Is Southern Nigeria a conquered territory? Are there no more men in the South that we will just roll on the floor and allow ourselves to be defiled?“

The Defendants not yet done with their ferocious attack went further to magnify their damages in the offensive publication as follows:-

“I remember that former President Olusegun Obasanjo once called for a psychiatric test for anyone aspiring to be the President of Nigeria. I am almost sure that if such a test is performed on Nasir El-Rufai, the results will shock Nigeria. And that is not hyperbole.”

11. My shock and unbelief sterns from the fact that the allegations contained in the said publication are a direct opposite of the character and person of the Claimant I have known over the years.
12. That upon reading the above publication, I could not resist having the impression that the Claimant, whom I had always held in very high esteem as a paragon of virtue and model of morality and public conscience was himself a selfish, power hungry, self-serving, religious and ethnic bigot, a violent loving person who sponsors violence and mindless death of innocent people of a different religious and ethnic stock to avenge the killings of his fellow Fulani Muslim and ethnic stock, a shameless schemer and mentally deranged person who would go to any length to acquire position of power.
13. That in view of the serious allegations levied against the Claimant I was forced to call the Claimant for explanations and he explained that the report was not true but borne out of spite and vindictiveness. He went further to inform me that he was contemplating a legal action against the Defendants in respect of the content of the publication.
14. All the allegations made by the 1st Defendant above which was published by the 2nd Defendant concerning the Claimant’s attitude towards Southern Nigeria women and men, people of other religious and ethnic background are false and does not in any way reflect the Character and person of the Claimant.
15. I have always known the Claimant as a peace loving and detribalized person who accommodates all Nigerians of all ethnic and religious background.
16. That I, MARY ADEOLA OLARERIN , solemnly and sincerely declare that I make this solemn deposition conscientiously in good faith believing contents of same to be true, correct and in accordance with the provisions of the Oaths Act, 2004 Laws of the Federation of Nigeria.
    …………………….
    DEPONENT