中土尼日利亚有限公司

CCECC NIGERIA LTD.

RC: 298534

20th July, 2022

The Principal Partner,
AUREOLE ATTORNEYS,
Block 17, Bola Badmus Street,
Badore, Lekki Phase 1,
Lagos.

ATTN: Adick Joshua Adick Esq.

Dear Sir,

RE: DEMAND FOR IMMEDIATE PAYMENT OF ACCIDENT COMPENSATION

TO MR AZEEZ AJAGBE WHILE IN YOUR EMPLOYMENT TO ENABLE HIM
UNDERGO A MAJOR OPERARTION (SURGERY)

We are in receipt of your letter dated the 1 st of July 2022 where you made false allegations
against the integrity of our company. Since you have failed to obtain the true state of the
matter from your client, you will find in the following paragraphs how the event played out.

Your client was involved in an accident at one of our sites on the 16 th day of August, 2021
where he sustained injury to his bladder as he was hit with an iron ring on his stomach. He
was immediately rushed to Jim-Sam Hospital, Ijora where he was admitted and minor
operations were carried out on him. He received treatment at Jim-Sam Hospital from the
time of the incident till November, a period of 3 months. All through this period, CCECC
bore all medical bills and every other associated costs.

Your Client, Mr. Azeez Ajgbe was later taken to the Lagos Island General Hospital, Lagos
Island in order to consult with an urologist. He was an outpatient an outpatient but goes
back for drugs and change of the catheter connected to his urinary tract. Due to the limited
numbers of specialists, a date in October, 2022 was scheduled for him to have the major
surgery – Urinary Tract Correction. We consider the date given too long thus he was taken
to the Lagos University teaching Hospital (LUTH) for examination. He was scheduled for
the corrective surgery on the 12th of July, 2022.

Your client later informed us that he will travel to Ilorin in a bid to get a closer date. The
response gotten from him was that the total sum for the surgery amount to about N320,
000:000 (Three Hundred and Twenty Thousand Naira) of which we offer to give him the
sum of N500, 000:00 (Five Hundred Thousand Naira) for the surgery. After this discussion,

Address: NO. 46, NnamdiAzikiwe Drive, Nigerian Railway Compound, Ebute Metta,
Lagos
E-mail: ccecc-xn@ccecc.com.cn
we heard no news from your client until a demand letter was gotten from your firm. A week
before the scheduled dated given at LUTH, we called your client to remind him to go for the
preliminary examination which was expected to be taken before the surgery. Your client
unequivocally stated that on the advice of his lawyers, he will no longer be going for the
surgery.

Contrary to what was alleged in paragraph 3 of your letter, your client never at any point
approached us for compensation whether verbally or in writing. What we find ‘strange,
annoying and inhuman’ is the advice given by your firm to Mr. Azeez against better
judgment preventing him from getting the needed surgery. As stated earlier, the sum of
N500, 000:00 offered to your client was for the surgery to be carried out in Ilorin according
to the request of your client. In fact, apart from bearing all the cost of medical bills and the
follow ups, we have been paying your client his basic salary since the incident. No
discussion whatsoever was had between us and your client as risk and hazard compensation
nor any on termination bonus.

If your client is still interested in carrying out the surgery, we are committed to paying the
sum to the full (at a government owned establishment) and/or wish that he be paid off, the
sum to be paid will be calculated according to the internal policy of our company.

Note also that we will not hesitate to report your firm to the Legal Practitioner’s
Disciplinary Committee for wrongly advising your client which could lead to loss of life
and in a bid to extort money from our company through your client.

Yours Faithfully,

xxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxx
CCECC NIGERIA LIMITED

Address: NO. 46, NnamdiAzikiwe Drive, Nigerian Railway Compound, EbuteMetta, Lagos
E-mail: ccecc-xn@ccecc.com.cn