Professional Documents
Culture Documents
AT NAIROBI
VERSUS
MEMORANDUM OF APPEARANCE
Please enter appearance for the 2nd defendant; SHARON NDETTO and NATION MEDIA GROUP in this suit
who’s address for service for the purpose of the suit shall be in the care of AMARCO &CO ADVOCATES 2 ND
FLOOR , SOUTHEND HOUSE , MUINDI MBINGU STREET ,NAIROBI PO BOX 92983-0100
NAIROBI
TAKE FURTHER NOTICE that henceforth , all further correspondence should be forwarded to the above firm of
advocates
AT NAIROBI
VERSUS
DEFENCE
1. Save as is expressly admitted herein the Defendants deny each and every allegation in the plaint as if the
2. The Defendants admits paragraph 1,2,3 of the plaint in so far as as the same are merely descriptive of the
parties herein save that their address for purposes of this suit of AMARCO &CO Southern End ,Muindi
3. The Defendants contend that the suit as filed does not disclose any cause of action against them and shall
accordingly apply at any appropriate time to have their names struck off from the suit with cost gainst the
4. The first and second defendants aver that paragraph 4 is true to the extent 1st defendant is the owner and
6. It is the Defandants assertion that the content in paragraph 6 are true .The Defendants further assert that the
published article is not false and malicious but factual and true and not defamatory in nature
7. Paragraph 7 of the Plaint have been denied and left for the Plaintiff to strictly proof
8. The Defendants is a stranger to paragraph 7 and asserts that the article was not in any way libellious but
very true
9. Contents of paragraph 8 are denied by the Defendants..No notice of apology was issued to the Defendants
and the Defendants avers that the Plaintiff be disentitled to the costs.
REASONS WHEREFORE the Defendants prays that the Plaintiff’s suit be dismissed with costs
JOB OWIRO…………………………………………………………………………………..PLAINTIFF
VS
The Defendants through assigned trial counsel ,hereby submits the following list of individuals who will or may be
CERTIFICATE OF SERVICE
I Winfred Wanjiru certify that I served a copy of the foregoing upon the following persons at the respective
addresses.
I did so on or before the date below by personal delivery or by first class mail with postage prepaid.
Dated……………………….,2018
REPUBLIC OF KENYA
JOB OWIRO……………………………………………………………….PLAINTIFF
Vs
1. I ,Emma Nasimiyu of P.O.BOX 3457-0200 Nairobi is a criminologist in Nairobi County Kibera area
.I make this witness statement from my personal knowledge in support of the Defendant Sharon
Ndetto .
2. I have been in this legal field for the past 18 years and practicing it in various legal firms in Nairobi
County.
3. The Defendant and I have grown together as we were from the same ageset and community back in
our hometown in Bungoma County.We have schooled together since primary school.
4. The Defendant has served in my father’s church back in the village as an usher as he is a born again
5. On the morning of 25/5/2018 , I read the article written by the 2 nd Defendant and written by the 1 st
Defendant and according to me the article was not malicious in any way.
6. I believe that the Defendant wrote the article based on facts and not on any other malicious matters .
EMMA NASIMIYU.
P.O.BOX 3562-0200
NAIROBI
REPUBLIC OF KENYA
VERSUS
AFFIDAVIT OF SERVICE
I, WINFRED WANJIRU of P.O.BOX 3527-0200 Nairobi , a duly authorized process server of the Chief
Magistrates Court ,do make an oath and state as follows:
1. THAT on the…………….day of ………………2018 at 1:00pm I served the defence in this case on JOB
OWIRO at his home in Valley Estate,Leo Street Nairobi by tendering a copy thereof to her and requiring a
signature on the original.He signed the summon was personally known to me as he identified me and even admitted
to me that he was the plaintiff in the case.
2. THAT not being able to find JOB OWIRO the plaintiff on the…………………..day of…………………..2018
at 1:00p.m, I served the summon on MRs OWIRO the wife to JOB OWIRO.
3.THAT not being able to find JOB OWIRO the plaintiff or any person whom the service could be made ,on
the……………………………………day of……………………2018 at 1:00p.m I affixed the copy of the defence to
the outer kitchen door of JOB OWIRO being the house she resides in.
4.THAT on the ………………………….day of………………..2018 at 3:00p.m I served the defence in this case
on JOB OWIRO in Valley Estate Leo Street Nairobi County a tendering a copy thereof to them and requiring a
signature on the original..
I was accompanied by BECKY KARANJA.
5.THAT{ Otherwise specify the manner in which the defence was served}
6.THAT all what is deponed herein is true to the best of my knowledge and belief.
WINFRED WANJIRU )
At Nairobi this……………………………. )
Day of…………………………………….2018 )
…………………………………..
BEFORE ME )
Agip House
Haile Sellasie
Nairobi
THE REPUBLIC OF KENYA
VERSUS
GLOBALMEDIA………………………………………………………………………..1ST DEFENANT
1.Emails
2,Text messages
3.A copy of the said Articled published and titled “ Act on this Cronyism ‘Lawyers tell Mutunga”
Agip House
P.OBOX 4563-0200
NAIROBI
TO BE SERVED UPON
Nairobi.
WINFRED WANJIRU KANYI
1032475
CIVIL PROCEDURE
CLS 203