- 17 - 6.7.10. The 3rd and the 4th Defendants have encouraged hate advertisement and documentaries against members of the opposition including the Plaintiffs and courted religious and ethnic division in Nigeria to ensure they do not lose the 2015 presidential election which has heated the entire polity and caused fear amongst the voting populace to the Plaintiffs detriment, outside the 1 st, 2nd and 3rd Defendants inability to contain and flush out insurgents in the Northern part of Nigeria to date, now affecting the Presidential election to the Plaintiffs detriment. 6.7.11. The Plaintiffs losses over the 3rd Defendant continued engineering of political uncertainties over the rescheduled Presidential elections and insecurity and inability to guarantee fair play and obedience to electoral laws are estimated well over $150 Million, most of which the Plaintiffs borrowed to prosecute the Presidential election out of its funds. 6.7.12. The Plaintiffs’ inclusion of the 4th Defendant in the present action is only as the 3rd Defendant’s sponsoring political party. The 4th Defendant is only attempting to divert attention from its 3rd Defendant presidential candidate and the elected sitting President at the 2015 presidential election. 6.7.13. The 4th Defendant is not entitled to the Orders it seeks as they are ungrantable in the circumstances of this case as a relevant and necessary party to this suit. 6.7.14. The 6th Defendant is not entitled to the relieves sought in objection as they are also a necessary party to this suit who have a duty to ensure due obedience to law and order and provide needed security as the civil authority saddled with the duty to ensure a free, fair and orderly conduct of the presidential election in Nigeria and the observers of all the electoral laws to prevent any violation of the Plaintiffs’ right to full participate and freely chose its representatives into government without any obstruction or intimidation of any kind which duty its has neglected, refused and failed to perform. 6.7.15. The Nigerian Judicial Workers strike was induced by the unwillingness of the 1st, 2nd, and 3rd Defendants to allow due financial autonomy and the independence of the Judiciary in Nigeria. 6.7.16. The Plaintiffs will at trial contend that its case is fully made out and established against the Defendants.

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