a. There is no paragraph in the narration filed in support of the substantive application which shows that the 1" Plaintiffis a juristic and only consists of member person duly registered countries of ECOWAS. b. The 1” Plaintiff lacks the Jocus stand/ to institute this action. CG The 2™ and 4" Plaintiffs’ claim is premature and cannot be maintained for it does not disclose any cause of action. d. The 3" Plaintiffs' claim is statute barred & The Plaintiffs/Respondents suit before this court is an affront to the internal sovereignty of the Defendant/Applicant. The Defendant supported the above objections with legal arguments and decided authorities. In response to the objection raised by the Defendant, the Applicants contends that the 1" Applicant is a legal person recognized and registered under Senegalese law. A proof of official registration was therefore attached and marked "Annex 1", The Applicants further pointed out that this Court has already granted standing to the |" Applicant in a previous proceeding; the 1" Applicant under its alternative name ' International Federation of Journalists Africa'- was the 3rd Applicant in the recent case of Hydara V. The Gambia, ECW/CCJ/APP/30/1 1. 12

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