precipitated militant retaliatory attacks by the heavy armed indigenous youths against the Defendant and the oil companies. The Plaintiffs further aver that the Defendant has fraudulently awarded oil and gas mining licenses/leases to both indigenous and non-indigenous firms some of whom have no prior experience or qualification in the upstream oil production and are even co-owned by a single individual with some of their family members, friends and associates. Some of the licenses were awarded for a long period of up to 20 years. The Plaintiffs state that this has not been done in accordance with the legal requirements. That the award of such contracts are lopsided, do not follow due process, and are evidently biased as most owners of the oil blocs are Northerners and Westerners while the Southerners have not been given any opportunity to benefit from what rightfully belongs to them. That the allocations were based on tribalism, nepotism, favoritism and frivolous whims and thus gives notice to the Defendants to produce a detailed information on how oil blocs mining leases were awarded, and also documents showing how and when the indigenous oil companies were incorporated, the incorporation documents as well as values of each shareholder. That the Defendant has perfected its plans to once again corner the impoverished and poverty stricken people of the Niger Delta by unilaterally renewing these same oil blocs licenses without recourse to the impact and damage the activities of the 5

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