/ Fer CeRvice on Ie Fend ant A : IN THE HIGH COURT OF JUSTICE OF KOGI|STATE OF NIGERIA sand aeanimuranarsoesssant NTHEKOGHSEATESUDIGIALDMISION evermore HOLDEN AT KOTON-KARFE ; ; SUIT NO: BETWEEN: {irading under the name and style ABDULLAHI YAHAYA DAZO } Of Abdullahi Dazo Yahaya Enterprise) | [ose ustetts «zstwwire ie “SOBANK NG ETB. ECO BANK PLC ee ooes You are hereby commanded that within 30 days after the service of this writ on you, inclusive of the days of such service, you do cause cn appearances jo be gntered for you in an action at the suit of ABDULLAH! YAHAYA DAZO and TAKE NOTICE that in default of your so doing, the claimdnt may proceed therein and judgment may b¢ given in your absence Os te bex...., Dated this aoc BYeORDER OF THE COURT = a Registrar — s 1 MEMORANDUM TO BE SUBSCRIBED ON THE WRIT: This writ is to be served within twelve calendar months from the date hereof or if renewed within six calendar months from the last renewal including the day of such date and not afterwards. The Defendants may enter appearance personally or by legal practitioner Py handing in the appropriate forms duly completed at the Registry of the High CourtoF _of the Judicial Division in which the action is va or by sending them to the “Registry by Registered post. : = ENDORSEMENT OF THE WRIT OF SUMMONS 1. The Clamant avers that sometimes around 2022 he applied for a loan facility from the defendant and was offered N5,000,000 [Five Million Naira) through the qecount detoils:.4110187702 - ABDULLAHI YAHAYA DAZO ENTERPRISE. 2, The Claimant avers that the loan facility was to qn for3 months, which actually | did run for 3 months and by the end of the thifd month, the loan facility was determined discharging both the claimant and the defendant from any further obligation in respect of the loan facility. : peescincrimanover thornton dtetietomchinnieamdannemns the claimant was subsequently given another loan facility without his consent and or knowledge until on the 26!" day of Janvary, 2024 when he got a mall from the defendant titled: "DEMAND FOR REFUND N5,000,000.00 ERRONEOUSLY CREDITED TO ACC NO 4110187702 - ABDULLAHI YAHAYA DAZO ENTERPRISE. 4. The claimant states that by a careful look at the letter of demand from the bank particularly poragraph 5 of the demgnd letter which states that “Consequently, we demand that you refund the|stated amount to the Bank on or before the close of business on February, 16, 2024, even though ihe Cicimont was not aware initially of the loan facility issued by the defendant, the claimant made sure he poy back the full Five Million Naira (N5,000,000.00) before ‘ne deadline set by the defendant, which was on Ist" February, 2024 leaving no default. 41 5, [tis the belief of the claimant that having paid the full N5,000,000.00 (Five Million Naira) os demanded by the defendant through fe defendant demand letter, the transaction between the claimant and the defendant was brought to an end. . : 6. The Claimant states that as at the time he paid the full payment of the loan amount, what was left in the claimant account| was N906.78 after which the Claimant credited the account with N30,000 making the available balance to be N30,724.21. 7. The Claimant states that to his dismay, on the 23° February, 2024 at about 1:41pm he got a transaction alert from the defendant of Five Million Naira __---{HH5,090,000.00) agcin and immediately the Five Million Naira N5,000,000.00 was debited from his account hence leaving the balance of N-4,969,275.79 Page 2 AO, MUSA & CO (THE PEOPLE’S CHAMBERS); 08105304778 osukujnr@gmail.crernannaencencettowencesstrreeerines nen eePHte A samnatonnssm ania tvOcCemeeen, which by simple arithmetic calculation shows that even the N30,724.21 which was in the claimant account was equally debited and which erroneously the defendant put the claimant in default of N-4,969,275.79 Four Million, Nine Hundred and Sixty-Nine Thousand, Two Hundred and Seventy-Five Thousand Seventy-Nine Kobo. _ The claimant states categorically that the said Five Million Naira N5,000,000.00 which was credited and debited almost at the same time was only fictitious as the money was not used by the Claimant nor did the Claimant access the amount. 9. The claimant states that noticing the fictitious.transaction, the claimant took steps to report the incident at the defendant's office in Lokcic, after which the claimant was told by one of the defendant customer care representatives that it was a system glitch which would be resolved. 10. The clamant states that after a week of the complaint nothing tangible was done about it by the defendant. 11-The Claimant slates that this unwarranted, unrealistic and unprofessional act of the defendant has caused him serious damage as same hindered him from accessing other loan facility from other banks by showing that the claimant is indebted to the defendant which is not true. 12. The claimant states that the unreasonable and fictitious transaction fabricated by the defendant against the claimant has put the claimant into economic Joss as the loan facility the claimant is expecting from one of the commercial banks has been put on hold, since the act of the defendant shows fictitiously that the claimant is indebted to the defendant and which is not true. 13.The Claimant states that he collected money from different customers amounting to Twenty-Five Million Naira (N25,000,000) and made © non: refundable deposit payment into NBC's (Nigerian Bottling Company) account for Coca-Cola’s products while expecting the loan the claimant applied for to make complete payment to the company in order to get the products for onward supply to the customers but because of the defendant's carelessness, the claimant could not get the loan he applied for from other banks fo complete the payment of the pioduct for the NBC's company ‘and the company did not supply the claimant the, products thereby putting the Glaimant in a serious embarrassment as the ¢laimant's customers started insulting the claimant with all manners of words while some are demanding for the refund of their money. 2 2 TO MUSA & CO (THE PEOPLE'S CHAMBERS); 08105304778 osukujnr@gmall.com. Page 3 |14, The claimant avers that up fill the 5 May, 2024, his mobile app is clearly > snowing that the claimant is sill indebted fo the defendant which is not true even though the letter of none indebtedness bes by the defendant to the claimant clearly shows that the claimant is not indebted to the defendant and equally the defendant apologized to the claimant for their wrongful act. 15. The clamant also state that the sedrch conducted from the Credit Burecu Limited shows also that the claimant is indebted to the defendant which is not true. 5 16, The claimant avers that he has suffered monetary loss in financing this tigation together with unnecessary inconveniences. WHEREAS THE CLAIMANT CLAIMS AGAINST THE DEFENDANT AS FOLLOW: 1, A DECLARATION that there is no existing loan contract between the claimant and the defendant in which repayment obligation right and recovery right respectively exist between them. 2, A DECLARATION that the defendant has been negligent, whose negligence has caused serious economic loses to the claimant for failure /refusal of the Defendant to remove/clear the indebtedness of N- 4,969,275.79 Four Million, Nine Hundred and Sixty-Nine Thousand, Two Hundred and Seventy-Five Thousand Seventy-Nine sKobo which the defendant concocted and placed on the account of the claimant without removing same despite the persistent complaint from the claimant to the defendant. 3. AN ORDER of the court compelling the Defendant to immediately remove/clear the sum N-4,969,275:79 Four Million, Nine Hundred and Sixty- Nine Thousand, Two Hundred and Seventy-Five Thousand Seventy-Nine Kobo which the Defendant put/placed on the Claimant's Account No: 4110187702 — ABDULLAHI YAHAYA DAZO ENTERPRISE carelessly causing economic damage to the claimant. 4, AN ORDER compelling the Defendant to, immediately refund to the claimant the sum of Thirty Thousand Seven Hundred and Twenty-Four Naira (830,724.21) which the Defendant fraudulently removed from the claimant's account and without the claimant's consent. 5. AN ORDER awarding the sum of Fifty Million Naira ($50,000, 000) being General Damages for the injury suffered by the claimant as a result of the Defendants Wrongful conduct against the defendant. KO. MUSA & CO (THE PEOPLE’S CHAMBERS); 08105304778 osukujnr@gmail.com. Page 46. Post-Judgement interest on the judgement sum of at the rate of 10% per annum until the final payment and or execution. 7. Cost of filing this suit. seers 2024, Dated the .... ...Day of This writ is issued by :U.F. MUSA , ESQ., whose address for service is AO MUSA & CO (THE PEOPLES CHAMBERS) 1574Murtala Muhammed Ways, Lokoja, Kogi State; with Phone Numbers: 08105304778 and Email: osukujnr@gmail.com. This writ was served by me alt. _on the Defendant (describe mode of service) on the ...........++day of . pabeni 024, Endorsed the sunday of .. . 2024, Signed .. % ACIESS seers The Registry, High Court of Kogi State in the Kogi State Judicial Division. A sufficient affidavit in verification of the endorsements on this writ to authorize the sealing thereof has been produced to me this... la is of... 024 i Page 5 RO. MUSA & CO (THE PEOPLE’S CHAMBERS); 08105304778 osukujnr@é!| IN THE HIGH COURT OF JUSTICE OF KOGI STATE OF NIGERIA IN THE KOGI STATE JUDICIAL DIVISION HOLDEN AT KOTON-KARFE ) SUIT NO:. BETWEEN: (trading under the name and style CLAIMANT Of Abdullahi Dazo Yahaya Enterprise) ABDULLAHI YAHAYA DAZO } AND ECO BANK PLC—- --DEFENDANT STATEMENT OF CLAIM 1. The Claimant is a businessman as a distributor with Nigeria Bottling Company (NBC) and resides in Lokoja within the jurisdiction of this Honorable court. 2. The 1% Defendant is a company duly registered with Corporate Affoirs Commission and licensed by Central Bank of Nigeria (C.B.N) and having its branch office in Lokoja within the jurisdiction of this Honourable Court . the Claimant avers that the cloimant maintains an account with the Defendant with account 4110187702 - ABDULLAH! YAHAYA DAZO ENTERPRISE 4, The Clamant avers that sometimes around 2022 the claimant applied for a loan facility from the defendant and was offered N5,000,000 {Five Million Naira) through the account detolls:_4110187702 - ABDULLAH YAHAYA DAZO ENTERPRISE. 5, The Claimant avers that the loan facilily was to fun for3 months, which actually did run for 3 months and by the end of the thitd month, the loan facility was determined discharging both the claimant and the defendant from any further obligation in respect of the loan facility. 6, The Claimant avers further that after the determination of the 1*! loan facility the claimant was subsequently given another loan facility without his consent nor knowledge until on the 26" day of January] 2024 when he got a mail from the defendant {itled: "DEMAND FOR REFUND N5,000,000.00 ERRONEOUSLY CREDITED TO ACC NO 4110187702 = ABDULLAH! YAHAYA DAZO ENTERPRISE. The letter of demand is pleaded and shall be relied|on during trial. 7. The claimant states that by a careful look at the letter of demand from the bank particularly paragraph 5 of the demand letter which states that o| “Consequently, we demand that you refund the stated amount fo the Bank on or before the close of business on February, 16, 2024, even though the Claimant wos not aware initially of the loan facility issued by the defendant, the claimant made sure he pay back the full Five’ Million gira ¢N5,000,000.00) before the deadline set by the defendant, which is on 16" February, 2024 leaving no default. The receipts of the various transactions are pleaded and shall be relied on duting trial. itis the belief of the claimant that having paid the full N5,000,000.00 (Five Million Naira) as demanded by the defendant through the defendant demand lester, the transaction between the claimant and the defendant was brought fo on end The Claimant states that as at the ime he paid the full payment of the loon amount, what was left in his account was N906.78 after which the Claimont credited the account with N30,000 making ‘the available balance to be 30,724.21. 10. The Claimant states that to his dismay, on the 23 February, 2024 at about I:dlpm he got a transaction alert from the defendant of Five Million Naira {§N5,000,000.00) again and immediately the Five Million Naira N5,000,000.00 wos debited from his account hence leaving the balance of N-4,969,275.79 which by simple arithmetic calculation shows that even the 430,724.21 which was in the claimant account was equally debited and which erroneously the defendant put the cloimant in default of N-4,969,275.79 Four Million, Nine Hundred and Sixty-Nine Thousand, Two Hundred and Seventy-five Thousand Seventy-Nine Kobo. 11 The cloimant states categorically that the said Five Million Naira N5,000,000.00 which was credited and debited almost at the same time was only fictitious as the money was not used by the claimant nor did the claimant access the amount. 12, The claimant states that noticing the fictitious transaction, the claimant took steps to report the incident at the defendant's office in Lokoja, after which the claimant was told by one of the defendant customer care representatives that it was a system glitch which would be'resolved.. | 13, The clamant states that after a week of the complaint nothing tangible was done about it by the defendant hence the Claimant instructed his lawyer fo write a solicitor letter dated 4" day of March,2024 intimating the defendant and © s0 TRO, MUSA & CO (THE PEOPLE'S CHAMBERS); 08105304778 osukujnr@gmail.com. Page 7asking the defendant to resolve the issue. The letter dated 4! March, 2024 and the annexures are hereby pleaded and shall belrelied on during trial. 14, The claimant avers that the defendant replied we claimant correspondence on the 7h day of March, 2024 stating that the defendant would investigate the issue and get back to the claimant even though there was no time limit for which the defendant would investigate. The letter dated 7" March, 2024 is hereby Pleaded and shall be relied.on during trial. 15. The claimant avers that in view of the fact that no time limit was given as to the conclusion of the investigation by the defendant, the claimant instructed his lawyer to write another solicitor letter dated 12" day of March, 2024 given the defendant two (2) days to investigate and recfify the issue. The letter dated 12" -isemeday of March 2024 is hereby pleaded and shall-be relied.on during trices 16 The claimant avers that the defendant replied the correspondence of the Claimant dated 12!" day of March, 2024 by their correspondence dated 14" . day of March, 2024 acknowledging that the defendant has done their interno! investigation and found that the claimant was not indebted to the defendant in anyway and equally tendering apology for the inconvenience the claimant suffered, The correspondence dated 14 day of March, 2024 from the defendant fo the claimant is hereby pleaded and shall be relied on during trial. 17. The claimant avers that even after the defendant acknowledges that the Claimant was not indebted to the defendant In anyway still from the mobile application provided by the defendant and also the search conducted from the credit bureau shows that the claimant was|still indebted to the defendant hence making the claimant not to be able to Mfithdraw money in the claimant account maintained by the defendant and also not been able fo access loans from any bank since it was stil shdwing that the claimant is indebted to the defendant. 18. The claimant avers that this act of the defendant made the claimant instruct his lawyer to write a solicitor letter dated the 25" doy, of April 2024 intimating the defendant of the claimant's intention to approach the court for redress. The correspondence dated 25" day of April, 2024 is pleaded and shall be relied on during trial. | 19. The claimant states that the defendant replied/the claimant's letter dated 25" day of April, 2024 by their correspondence sn 7h May, 2024 acknowledging nena gh. minting, furiner.jnol the cleimonl not incebted fone celensea. ‘AO. MUSA & CO (THE PEOPLE'S CHAMBERS); 08105304778 osukt jinr@gmail.com.eh ASIC IS OO VE TST EEL OTE T IA SMS PE MOR SSRN ESERIES anyway. Their correspondence dated 17 day of May, 2024 is pleaded and shall be relied on during trial. : 20. The claimant states that even after the defendant confirmed that the elaimant was not indebted to the defendant stil the search conducted from ihe credit Fureay and also from the mobile App provided also show the claimant to be indebted to the defendant which is not true. 21. The Claimant states that this unwarranted, unrealistic and unprofessional act of the defendant has caused the claimant serious damage as same hindered the claimant from accessing other loan facility from other banks by showing that the claimant is indebted to the defendant which is not true. 22. The claimant states that the unreasonable and fictitious transaction fabricated by the defendant against the claimant has put the claimant into economic loss cathe loan facity the claimant is expecting from one of the commercial banks has been put on hold, since the act of the defendant shows fictiiously thot the claimant is indebted to the defendant which is not true. 23, The Cloimant states that he collected money from different customers qmounting to Twenty-Five Million Naira (N25,000,000) and made a non. refundable deposit payment into NBC's (Nigerian Bottling Company) account for Coca-Cola's products while expecting the loan the claimant applied for to make complete payment to the company in order to get the products for onward supply to the customers but because of the defendant's carelessness ~tne-clgimant ‘could: not “get the-foarr’he applied-for-from other banks 10 complete the payment of the product for tne NBC's company and the company did not supply the claimant the products thereby putting the Claimant in a serious embarrassment as the claimant's customers started insulting the claimant with all manners of words while some ore demanding for the refund of their money. The demand letters dated 1# day March, 2024 and 4h March, 2024 from the claimant customers are hereby pleaded and shall be relied on during trials. 24, The claimant avers that up fill the 5* May, 2024, the claimant mobile app is clearly showing that the claimant is sil indebted to the defendant which is not true even though the letter of none indebtedness issued by the defendant dated 14 March 2024 fo the cloimant clearly shows that the claimant is not indebted to the defendant and equally the defendant apologized fo the clcimant for the defendant wrongful act. The letter of non- indebtedness dated FO MUSA & CO (THE PEOPLE'S CHAMBERS); 08105304778 osukujnr@email.com14h March, 2024 issued by the defendant to the claimant is pleaded and shall \ be relied on during trial 25. The clamant also state that the search conducted from the Credit Bureau i Limited shows also that the claimant is indebted to the defendant which is not jrue 26. The claimant avers that he has suffered monetary loss in financing this litigation together with unnecessary inconveniences. 27. The Claimant avers that he paid Seven Hundred and Fifty Thousand Naira | (§N750,000) as legal fee to prosecute this suit. WHEREOF: The Claimant claims against the defendant as follows: 1. A DECLARATION that there iseno existing loan contract between the claimant and the defendant in which repayment obligation tight and recovery right respectively exist between them. 2. A DECLARATION that the defendant has been negligent, whose negligence has cause serious economic loses to the claimant for failure/refusal of the Defendant to remove/clear the indebtedness of N-4,969,275.79 Four Million, Nine Hundred jand Sixty-Nine Thousand, Two Hundred and Seventy-Five Thousand Seventy-Nine Kobo which the defendant concocted and placed on the account of the claimant without pecmiuansenstemoving.same despite the persistent complaint from. the claimant to:thes 2 defendant. 3. AN ORDER of the court compelling the Defendant to immediately remove/clear the sum N-4,969,275.79 Four Million, Nine Hundred and Sixty- Nine Thousand, Two Hundred and Seventy-Five Thousand Seventy-Nine Kobo which the Defendant put/placed on the Claimant's Account No: 4110187702 — ABDULLAH| YAHAYA DAZO) ENTERPRISE carelessly causing economic damage to the claimant. (i 4, AN ORDER compelling the Defendant to immediately refund to the claimant the sum of Thirty Thousand Seven Hundred and Twenty-Four Naira (M30,724.21) which the Defendant | fraudulently removed from the claimant’s account and without the claimant's consent. FO, MUSA & CO (THE PEOPLE'S CHAMBERS); 08105304778 osukujnr@gmail.com. Page 105. AN ORDER awarding the sum-of Fifty Million Naira ($50,000, 000) being General Damages for the injury suffered by the claimant as a result of the Defendants Wrongful conduct against the defendant. 6. Post-Judgement interest on the judgement sum of at the rate of 10% per annum until the final payment and or execution. 7. Cost of filing this suit. Dated this .........0+ day of ZL. HUSSAINI ESQ SALIHU ABDULMALIK ESQ Y.M JAMIU ESQ. |. H HUSSANI ESQ. M.U AHMED ESQ. M.A AHMED ESQ ULF. MUSA ESQ M.A. MUSA ESQ | A.O MUSA & CO | (The People's Chambers) 1574 Murtala Muhammed way Lokoja, Kogi State. 08105304778. osukujnr@gmail.com FOR SERVICE ON Eco Bank PLC Lokoja, Kogi State. ‘A.0. MUSA & CO (THE PEOPLE’S CHAMBERS); 08105304778 osukujnr@gmall.com.IN THE HIGH COURT OF JUSTICE OF KOGI STATE OF NIGERIA IN THE KOGI STATE*JUDICIAL DIVISION HOLDEN AT KOTON-KARFE : SUIT NO:.. BETWEEN: (trading under the name and style CLAIMANT Of Abdullahi Dazo Yahaya Enterprise} ABDULLAH! YAHAYA DAZO } AND 1 ECO BANK PLC----— ----DEFENDANT TAKE NOTICE that the Claimant shall give evidence and call the following witnesses at the hearing of this suit: 1, ABDULLAHFYAHAYA DAZO (The Claimant) + 2024 Dated this wen day Of « Wuee Z.L. HUSSAINI ESQ SALIHU ABDULMALIK ESQ Y.M JAMIU ESQ. |. H HUSSANI ESQ. i M.U AHMED ESQ. M.A AHMED ESQ UF. MUSA ESQ <_-M.A. MUSA ESQ A.O MUSA & CO (The People’s Chambers) ja Muhammed wayFOR SERVICE ON | ECO BANK PLC, Lokoja, Kogi State PLES CHAMBERS); 08105304778 osukujnr@gmall.com. Page 13, ‘A.. MUSA & CO (THE PEOIN THE HIGH COURT OF JUSTICE OF KOGI STATE OF NIGERIA te” IN THE KOGI STATE JUDICIAL DIVISION HOLDEN AT KOTON-KARFE SUIT NO:. | BETWEEN: ABDULLAHI YAHAYA DAZO. (trading under the name and style ———=- —--CLAIMANT i ¢ engine | ase sn OREO EOE AND ECO BANK PLC———— —-DEFENDANT \ CLAIMANT ‘S STATEMENT ON OATH |, ABDULLAH] YAHAYA DAZO, Male, Adult, Muslin, businessman as Distributor of Nigeria Bottling Company, Nigerian of no 4 Oba Michael road, Lokoja do hereby | make oath that: ° 1. 1am the Claimant in this matter by virtue of which |am conversant with the facts deposed in this deposition on oath. 2, The 1" Defendant is a company duly registered with Corporate Affairs Commission and licensed by Central Bank of Nigeria (C B.N} and having its branch office in Lokoja within the jurisdiction] of this Honourable Court. 3. | maintain an account with the Defendat it with account 4110187702 - ABDULLAHI YAHAYA DAZO ENTERPRISE |. The loan facility was to run for 3 months, whith actually did run for 3 months and by the end of the third month, the) loan facilily was determined discharging both me and the defendant| from any further obligation in respect of the loan facility. After the determination of the 1* loan facility | was subsequently given another loan facility without my consent nor knowledge until on the 26" day of January, 2024 when! gota mail from the defendant titled: “DEMAND FOR REFUND N5,000,000.00 ERRONEOUSLY CREDITED TO ACC NO 4110187702 — ABDULLAHI YAHAYA DAZO ENTERPRISE. The letter of demand is pleaded and j shall be relied on during trial. ammeneeg BY EERSTO! TOORC! THE EMEP OP SBMA “HORM INE BOAR BUMIEOTETI paragraph § of the demand letter which| states that "Consequently, we demand that you refund the stated amount fo the Bank on or before the Close of business on February, 16, 2024, even though | was no! ewor® initially } of the loan facility issued by the defendant, | made sure | pay back the full = a CHAMBERS); 08105304778 osul Page 14Five Million Naira €N5,000,000.00) before the deadiine set by the defendant, whichis on 16" February, 2024 leaving no default. The receipts of the various transactions showing the payment | made are pleaded and shall be relied ‘on during trial. = |. Itis the belief that having paid the full 'N5,000,000.00 (Five Million Naira) as demanded by the defendant through the. defendant demand letter, the transaction between me and the defendant was brought to an end. 8. That as at the time | paid the fullpayment of the loan amount, what was left | in my account was 906.78 after which | credited my account with N30,000 making the available balance to be N30,724.21. 9. That to my dismay, on the 236 February, 2024 at about 1:41pm | got a transaction alert from the defendant of Five Million Naira (N5,000,000.00) again and immediately the Five Million Naira N5,000,000.00 was debited from my account hence leaving the balance of N-4,969,275.79 which by t simple arithmetic calculation shows that even the 30,724.21 which was in my account was equally debited and which erroneously the defendant put ne ssnmee HSH CSTAUIT “OP NG 96 8278:77- POUT MISH NINE HUH ATES BH SIRTY-NIRNE ve Thousand, Two Hundred and Seventy-Five Thousand Seventy-Nine Kobo 10. The said Five Million Naira N5,000;000.00 which was credited and debited almost at the same time was only fictitious fas the money was not used by me nor did | access the amount. | . Noticing the fictitious transaction, | took steps to report the incident at the defendant's office in Lokoja, after which | w@s told by one of the defendant customer care representatives that it was 4 system glitch which would be resolved. ? 12. After a week of the complaint nothing tangible wos done about it by the defendant hence | instructed my lawyer jo write a solicitor letter dated 4" day of March,2024 intimating the defendant and asking the defendant to resolve the issue. The letter dated 4!" March, 2024 and the annexures are hereby pleaded and shall be relied on during tral. 13. The defendant replied to my correspondence on the 7!" day of March, 2024 stating that the defendant would investigate the issue and get back to me even though there was no time limit for which the defendant would investigate. The letter dated 7!" March, 2024 is hereby Pleaded and shall be relied on during trial. “ TO, MUSA & CO [THE PEOPLE'S CHAMBERS); 08105304778 osukujnr @email.com Page 15,14. In view of the fact that no fime limit was given as to the conclusion of the investigation by the defendant, | instructed my lawyer to waite another solicitor letter dated 12 day-of March, 2024 given the defendant two (2) days to investigate and rectify the issue. The|lelter dated 12" day of March 2024 is hereby pleaded and shall be relied on during trial. The defendant replied my correspondence’dated 12h day of March, 2024 by their correspondence dated 14" day of March, 2024 acknowledging that the defendant has done fheir internal investigation and found that | was not indebted to the defendant in anyway and equally tendering apology for the inconvenience | suffered. The correspondence dated 14mm day of March, 2024 from the defendant to the claimant is hereby pleaded manson gid $hall BE Yelled on duiing tign™ 16. Even after the defendant acknowledges that | was not indebted to the defendant in anyway still from the mobile application provided by the defendant and also the search conducted from the credit bureau shows that | was still indebted to the defendant hence making me not to be able to withdraw money in my account maintained by the defendant and also not been able to access loans from any bank since it was sfill showing that | was indebted to the defendant | 17. This act of the defendant made me instru¢t my lawyer io write a solicitor letter dated the 25" day, of April 2024 intimating the defendant of my intention to approach the court Tor redress. The correspondence dated 25" day of April, 2024 is pleaded and shall be relied on during trial. 18. The defendant replied my letter’ dated 25" day of April, 2024 by thelr correspondence dated 7 May, 2024 acknowledging and maintaining further that | am not indebfed to the| defendant in anyway. Their correspondence dated 17" day of May, 2024 Is pleaded and shall be relied on during trial. | 19. Even after the defendant confimed thet | was not indebted to the defendant stil the search condycted from the credit Bureau and also from the mobile App provided also show that | was indebted fo the defendant x a which is not true. 20, This unwartanted, unrealistic and unprofessional act of the defendant hos caused me serious damage as same hindbred me from accessing other saan tunusloan facility. from other banks by showing that | am stil indebted.to. ine defendant which is not true. "0, MUSA & CO (THE PEOPLE’S CHAMBERS); 08105304778 osukyjnr@e Page 16