PM Kamla Persad Bissessar Pre-Action Protocol To Patrick Manning

Devesh Maharaj & Associates ‘Attorneys at Law Consultants: Frank D. Solomon S.C. Sonny G, Maharaj S.C. Mansfield Chambers, Mansfield House (Fits Flor), No, 24 Aberromby Steet, Port of Spain, Attorneys Devesh Maharaj LLB Trinidad, West Indies. Kandace Bharath LLB Phone No. 270174 Jenelle M. Joseph LLB 624.8567 Angela Z. Mohammed LLB Fax No, 6278191 Exmail devmaharaj@rstt.net.t¢ Our Ref Your: Re November 19, 2010 The Honorable Patrick Manning Member of Parliament for San Fernando East GTM Insurance Building, Coffee Street, SAN FERNANDO. Dear Sir, Re: Defamatory statements made by Mr. Patrick Manning We have been instructed by the Honorable Prime Minister Mrs. Kamla Persad Bissessar in connection with statements made by you which were reported in an article published on page 5 of the Newsday Newspaper of Saturday, November 13, 2010 under the headline “Manning attacks Govt”. The said article which was printed under the byline of one Andre Bagoo was continued on page 15 of the said newspaper under the further headline "Manning: SIA did good job”. ‘As is well known, Prime Minister Kamla Persad Bissessar is the leader and head of the Peoples’ Partnership Government. ‘These statements were made in a press conference called by you outside of the Parliament Chamber. ‘The article reports that you told reporters ”..that the present People’s Partnership Government was dismantiing the security services of the country to pay back drug-lords who had financed their campaign for the May 24 General Election”. ‘Any such statement made by you is false and malicious and calculated to injure our client's reputation in her public and private capacity. ‘The article also reports that you made the following statements:- wl?Page 2 November 19, 2010 The Honorable Patrick Manning %.... have been taking very careful note of the actions of the Government. The Government has been systematically dismantling the institutions of the State that are involved in the anti-drug effort. And removing from office key people involved in the anti-drug effort. And at first I took note of that and wondered if it was coincidental and as time has gone on that is becoming clearer to me.” “And I would tell you something else: it makes sense when you take into account the amount of money that the UNC-led coalition was able to expend in the campaign. The question arises from what sources did this money come? From what sources did this money come? And if a clear case can be made out — and I am going to make this case in Parliament ~ much of it came from drug sources then what you are seeing now is the pay back by the Government and that the Government of Trinidad and Tobago is taking the country down a road that the narco-dealers will have a major hand in the conduct of State.” ‘The article reports that you made the following further statement:- “I am very concerned that essentially the SIA is going to be dismantled from what the Prime Minister has said, and they have dismantled the intelligence monitoring capability of SAUTT... In their natural an ordinary meaning and/or by way of innuendo, the words used by you meant and were understood to mean that our client and/or the Peoples’ Partnership Coalition, of which she is the leader, received financial contributions or assistance from drug lords and/or drug dealers and/or that she or Peoples’ Partnership Coalition are in their debt and that it is for this reason that she has exposed in Parliament the wire tapping activities of the SIA; and additionally, the said words meant or were understood to mean that our client was a party to a criminal conspiracy the purpose of which was to facilitate criminal activities of drug dealers and/or drug lords by compromising or weakening security agencies of the state. In the circumstances, our client requires the followi 1. An unqualified withdrawal of the allegations referred to above and a proper apology to our client in terms to be agreed. 2. An undertaking by you not to repeat the allegations or similar allegations. 3. The payment of a substantial sum in damages to our client to demonstrate the baselessness of the allegations and to compensate our client, for the injury to her reputation and considerable distress that has been caused. 13Page 3 November 19, 2010 ‘The Honorable Patrick Manning 4, The payment of our client's legal costs. If you are prepared to withdraw promptly the allegations and apologise, our client acknowledges that this will mitigate the damages to which she is entitled. If, however, you force her to go through a long and drawn out libel action in order to clear her fame, her only vindication will be an award of very substantial damages from the Court. Our letter is being sent to you in accordance with the pre-action protocol set out on the Practice Direction issued by the Honorable Chief Justice on November 15, 2005 Pursuant to the Civil Proceedings Rule 1998 (As Amended) in an effort to avoid litigation. rs faith DEVESH| MAHARAJ

PM Kamla Persad Bissessar Pre-Action Protocol To Patrick Manning

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

PM Kamla Persad Bissessar Pre-Action Protocol To Patrick Manning

Uploaded by

Copyright:

Available Formats

You might also like