MD & CO ADVOCATES

P.O. BOX 769, DODOMA-TANZANIA. MOB: +255 752 737 498/ +255 789 138 818
SHOPPERS PLAZA COMPLEX, / DODOMA STREET
Email: md&co@gmail.com

REF: MD&C0/ADS/DEMAND/01/12 12nd January 2021

DIRECTOR,
MAKULU NATIONAL HOSPITAL
P.O. BOX 1234,
DODOMA.
Dear Sir/Madam,
REF: DEMANDING PAYMENT OF THE SUM OF TSHS 502, 000, 000 AS
COMPENSATION FOR THE LOSS YOU HAVE CAUSED.
The above taken subject matter is to be considered.
We are MD AND CO ADVOCATES acting under instructions of MR KITO MARI (herein
referred to as our client) to demand from you the promptly and immediate settlement of the
claims concerning our client interests.

We would like to remind you on the particulars of the claims as follows:

1. That, on 1st October, 2020 our client was brought at your hospital when he got sick in
course of his employment. And that our client was admitted by the doctor who drawn an
ED and gave it to our client in order to seek an ample time to attend the treatment from
the employer.
2. That, our client submitted the issued ED to his employer so that he could be excused
from duties as it was recommended by the hospital and on receipt the employer became
suspicious of the authenticity of the document and thereafter wrote a letter dated on 3 rd
October, 2020 with Ref No. WPC/EF.20/12/40 to you asking if the document was really
drawn by the hospital
3. That, on response to the letter, the Hospital issued a letter dated on 5th October, 2020 with
REF No. MNH/OP/100/09 denying to have issued our client with the said ED and
provided that the same might have been forged by our client for his desired purpose.
4. That, following the denial our client was charged with disciplinary offences namely
forgery and being dishonest to the employer and subjected into staff disciplinary
 committee which found him guilty and recommended his termination from employment
and therefore, the employer acted effectively to the recommendation and terminated our
client from the employment by issuing a letter of termination dated 1 st December, 2020
with ref. No. WPC/CF.50/210/02/225.
5. That, the termination of our client from employment was resulted from information given
by your Hospital of denying to have been issued with our client the ED and adding the
fact that such purported document might have been forged.
6. That, we are also conversant of your attempt to correct the information issued to the
employer using the letter dated on 4 th December, 2020 with Ref. No. MNH/100/12 after
realizing that the previous information which denied the ED was incorrect and that the
ED was really drawn by the doctor who was working in the Hospital
7. That, you thereafter tried to make good the bad but with no merits because our client was
already terminated and the employer did not show any response to you when you wanted
to correct miss-information.
8. That, following the termination our client has suffered various losses including ruined
reputation for being labeled as fogerer, financial loss for unpaid remunerations for the
remaining period of thirty-six (36) months (that is to say 9,500.000 *36 =342,000,000)
before his compulsory retirement, gratuity payable to the retired employee amounting to
Tshs. 160,000,000/=

WHEREFORE, we are demanding you to settle the claim by making payment of the total sum
of 502, 000, 000 (say Five Hundred and Two Million Shillings Only) to our client being the loss
for unpaid remuneration of 36 months before his compulsory retirement and the gratuity payable
to the retired employee. BE WARNED THAT, unless you settle the matter within fourteen (14)
days from the date of demand, we will take the legal action which shall have no merits on your
institution and you will be required to bear the costs of the suit.

You are so demanded

Yours Faithful
………………………
M. Isack
(CHIEF ADVOCATE)
COPY TO:
1. OUR CLIENT