In the reply dated the 20th day of June, 2018, Mr. Felix stated that before the receipt of the letter, the matter had already been filed before the court, and that most of the allegations contained in Mohammed I. Tsav’s letter of June 4th 2018, that necessitated NBA’s letter to him, are part of the issues he is seeking determinations of in the said suit, therefore he intends not addressing same. However he stated some facts which to his knowledge are the true state of events that occurred. According to him, he did not bring to June 1st meeting of NBA Bwari any non lawyer, rather it was Mohammed Tsav, and his cohorts who met on 25th of May at Sukale Garden that imported none lawyers and some members of Living Faith Church Lawyers fellowship, to attend the said meeting, to give him muscle to carry out further abuse of the Bye Law. He affirmed that Mr. Tsav has severally acted outside the law contrary to the uniform bye-laws which should not be tolerated. “The purported motion to remove me as Secretary was not in accordance with provisions of the Bye Law, particularly Section 14(1) (f) and subsection 5. Mohammed Tsav, Esq emboldened by the non lawyers he imported, refused for verification of members in attendance but insisted that voting shall be done by show of hands. “A counter motion was moved by Pascal Jiwuaku, Esq, pointing out that the motion was manifestly incompetent as it was not on the agenda of meeting but Mohmmed Tsav, Esq insisted that a vote must be taken. When he couldn’t have his way, Mohammed Tsav took the minute’s book and gave it to a man he claimed is the new Provost of the Branch, the attendance register suffered the same fate and his hired thugs broke down the meeting. “Contrary to Section 14 (3) Mohammed Tsav, Esq with held the resignation of Sadiq Nwabueze, Esq as the Provost of the Branch and without consultation with the Executive or conducting a bye-election (see Section 14 (2)(b), announced on June 1st, 2018, the appointment of Provost to replace Sadiq Nwaubeze, Esq who had submitted his letter of resignation to the Chairman since January, 2018. This illegal appointment of a Provost, was to provide muscle for the violence he and his cohorts had already planned. “I had in my letter of 27th November, 2017, informed you of the plans by Mohammed Tsav, Esq to use violence to remove me as Secretary of NBA Bwari. The letter is in the bundle marked “B.” Like his behavior in November, 2017, he brought in armed policemen, to supervise and intimidate members with intent to cow them from reasoning with the Bye Law and advancing quality debate,” he said. He also stated his disappointment over the Secretariat’s acknowledgement to Mohammed Tsav’s letter written on NBA Bwari letter headed paper that bears, L.J. Ahmad and M.C. Uzoukwu’s names as Ex Chairman and Ex Secretary of NBA Bwari. In support of his assertion, Mr. Felix attached, the letter of the General Secretary, dated September 19th, 2017 wherein it was clarified that past Chairman and Secretary of Committees, are not recognized as past Chairman and Secretary of any Branch. He further noted that he who seeks equity must first do equity and that Mohammed Tsav, Esq cannot seek his audience, intervention and protection, without first respecting the General Secretary’s office by complying with his directive in the said letter; a directive given over clear nine (9) calendar months ago. TheNigerialawyer (TNL) recalls that a motion for the removal of Mohammed Tsav, Esq signed by five (5) financial members had been served on Mohammed Tsav, Esq on the 22nd day of May, 2018, ten clear days before June 1st 2018.]]>

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