The Plaintiff went on to say that it received the Defendant’s approval to rehabilitate
a portion of Jui Port that was not in use and reclaimed over ten thousand square
metres (10,000m2 ) of land adjacent to the Port that was eroding. According to the
Plaintiff, it also constructed an additional entrance into the Port, repaired and
secured the two large hangers and repaired and maintained the Road connecting
Jui Port with the main highway to Kissy. Furthermore, the Plaintiff said it helped the
Jui Community with the Construction of a Mosque, the installation of a new well,
and went as far as supplying a fishing boat with fishing nets and motor.
The Plaintiff’s case is that it received an order from its first customer, Theodore
Nagel (Germany), around the middle of January, 2008. The order was for four
thousand cubic metre (4,000m3) of mixed species with a value of One Million, Two
Hundred Thousand Dollars ($1,200,000 USD). It said Theodore Nagel also indicated
that they would be interested in purchasing ten thousand cubic metre (10,000m3 )
of mixed species each month going forward.
According to the plaintiff’s pleadings, in March 2008, the Defendant breached the
Agreement when it decided to illegally stop the Plaintiff from exercising their rights
as outlined in the Agreement. The breach caused severe damage to the Plaintiff
and robbed Defendant’s citizens of much needed jobs. The plaintiff stated further
that even though the Defendant illegally banned logging operations in March 2008,
there were assurances that the ban would be lifted. According to the plaintiff, on
account of the illegal breach of the Agreement, it was forced to stop work. Plaintiff
said it had depleted its working capital after nearly a year of Defendant’s delays
3