You are on page 1of 3

Scripture Union Centre, 2nd Floor Rm 202, Argwings Kodhek Road, Hurlingham, P.O.

Box 29166 - 00100 Nairobi, Cell: +254 737 861 093 E-mail: info@chelangadvocates.com

&COMPANY

CHELANGA
ADVOCATES

Robert

Alai

NAIROBI

We act for Dennis address

Itumbi

("our client")

in relation

to the aboye matter

on whose

instructions

we

you as hereunder. lO'J, to l4'J, March 2012, you published or caused to be published to our client: Hriting mistakes In your twitter

That betvveen

and facebook account

the following

words about and referring

"Jmt reading this "Leaked Diplomatic ond Moses Kurio on it"

Memo".

You can just see the hone! ond common

of ftumbi

" ... don't gil'e ltumbi propaganda" "Some primitil'e

and IV/oses Kurio much airtime

I-lith these Joke documents

they c/uthor ond distribute Jar

chauI'inist

who ,-,ish to scure Kiboki into not handing

ol"er power I\'ith such Jake memos. Ati

/ce

want to arrest Kibaki"

The above words Wide Web.

have the potential

of being re-published

to limitless

numbers

through

the World

It was within

your
~

knovvledge
L

that the above to disparage and contempt and the

offending
L

words

are false. Your credit,

publication reputation

of the standing his natural

same was malicious

and calculated odium

and injure our client's capacity in that,

and bring

him to public scandal, and to cast aspersions associates meaning,


,

in his personal Government

and in his professional in their ordinary and

on his integrity colleaaues ~ intended

and suitability
b

in the eyes of the public, to mean,

his employer,
~

professional

the said vvords rneant,

to mean and vvcre understood

that our client:

g)

intends power;

to destabilize

Kenya bv encouraging

the incumbent

president

fi-om handing

over

Our client is an upstanding he is an international continental The County the holder competence. As a consequence suffered Newspaper. is rightly Media Think

member

of the society as Bureau

with long service Chief with South of County integrity,

to the media and in particular Africa's Journalism.co.za, position wherein a by the Title and professional

journalist

working

Tank and also owns a group The position he currently to be of unquestionable

Based Newspapers sensitive standing moral

holds is an extremely

expected

of vour conduct, distress

our client's

reputation

has been seriously his career,

damaged,

and he has Our

considerable

and embarrassment

to himself,

calling,

and family.

client

has suffered

and continues

to suffer words.

a loss of reputation

as a direct

consequence

of your

publication

of the said offending

(1)

An admission words;

of liability

for false and malicious

puhlication

of tl1l' aforestated

offending

(3)

Issuance

of an appropriate

apology

to our client to be published

in the same media,

the

text of which ,\'e shall approve Further, offending quantum we are instructed words,

prior to such publication.

to put you on notice that our client holds you liable for any and all injury by him in consequence
. L

and loss suffered


I...-

or incurred and require'S

of the false and malicious


\:'>...

publication

of the the

vou to give an undertakilw

to pav damages "-

in resl)ect

thereof,

of which shall be communicated

to you in due course. from you (1) the admission of liability and instructions \\ithout undertakings reference

TAKE NOTICE that if we do not receive


in terms proceedings of (2) and (3) above against within you for (1) defamation

Seven (7) days hereof,


and (2) malicious incidental

our

are to institute further

falsehood, thereto.

to you, and at your risk as to costs and consequences Yours faithfully,

CHELANGA & CaMp.

You might also like