IN THE FEDERAL HIGH COURT
IN THE LAGOS JUDICIAL DIVISION
HOLDEN AT LAGOS
CHARGE NO: FHC/L/553C/2015
BETWEEN:
THE FEDERAL REPUBLIC OF NIGERIA ……COMPLAINANT/APPLICANT
AND
1. 
GOVERNMENT
EKPEMUPOLO
GOVERNMENT
EKPEMUPOLO
(ALIAS TOMPOLO)
2. PATRICK ZADEKE AKPOBOLOKEMI ……DEFENDANTS
3. GLOBAL WEST VESSEL SPECALIST LTD
4. ODIMIRI ELECTRICALS LTD
5. KIME ENGOZU
6. BOLOBOERE
PROPERTY AND ESTATE LTD
7. REX ELEM
8. DESTRE CONSULT LTD
9. GREGORY MBONU
10. CAPTAIN WARREDI ENISUOH
MOTION EXPARTE
BROUGHT UNDER
1. SECTION 80 AND 81 OF THE ADMINISTRATION
OF CRIMINAL JUSTICE ACT, 2015
2. AND UNDER THE INHERENT JURISDICTION OF
THIS HONOURABLE COURT
TAKE NOTICE that this Honourable
Court shall be moved on the ………. of …………….. 2016 at 9.0’clock in the forenoon
or so soon thereafter as counsel to the Complainant/Applicant will be heard on
behalf of the Complainant/Applicant praying the Honourable court for the
following:
1.
AN ORDER of this Honourable
Court pursuant to Section 80 and 81
of the Administration and Criminal Justice Act, 2015 authorizing the Economic And Financial Crimes Commission to attach
the following properties belonging to Government Ekpemupolo (alias Tompolo) named as 1st
Accused herein by seizure pending the arrest and/or appearance before this
Honourable Court and arraignment of the 1st Accused:
(i)
Property at No. 1 Chief Agbamu Close DDPA
Extension Warri (Effurun), Delta State.
(ii)
All properties of Mieka Dive Ltd and Mieka
Dive Training Institute Ltd situated at No. 77, Lioth Street, ODPA Ugborikoko,
Uvwie Local Government Area, Delta State.
(iii)
All properties of Global West Vessel
Specialist Ltd.
(iv)
All properties of Muhaabix Global Services
Ltd.
(v)
A River Crew Change Boat named MUHA – 15
(vi)
The property known as “Tompolo Dockyard”, by
the end of Enerhen Road, Effurun, Warri.
(vii) The
property known as “Tompolo Yard”, at the end of Chevron Clinic Road, next to
Next Oil, Edjeba, Warri.
(viii) The
Diving School at Kurutie, at Escravos River.
(ix)
The property known as “Tompolo House” at
Oporaza Town, opposite the Palace.
(x)
Any other property discovered by the Economic
And Financial Crimes Commission, moveable and immoveable, belonging to the 1st
Accused person.
2.
SUCH FURTHER ORDER OR
OTHER ORDERS as
this Honourable Court may deem fit to make in the circumstances of this case.
Dated this 18th
day of February, 2016
FESTUS KEYAMO, ESQ.
PROSECUTING COUNSEL FOR THE
ECONOMIC AND FINANCIAL CRIMES COMMISION
C/O FESTUS KEYAMO CHAMBERS
1, FESTUS KEYAMO LANE,
BEHIND HOTEL NEWCASTLE,
OFF ADEBAYO MOKUOLU STREET,
OFF GBAGADA EXPRESSWAY,
ANTHONY VILLAGE,
LAGOS STATE.
08033371229, 08055028515
festuskeyamochamberslag@yahoo.com
IN THE FEDERAL HIGH COURT
IN THE LAGOS JUDICIAL DIVISION
HOLDEN AT LAGOS
CHARGE NO: FHC/L/553C/2015
BETWEEN:
THE FEDERAL REPUBLIC OF NIGERIA ……COMPLAINANT/APPLICANT
AND
1. GOVERNMENT
EKPEMUPOLO
GOVERNMENT
EKPEMUPOLO
(ALIAS TOMPOLO)
2. PATRICK ZADEKE AKPOBOLOKEMI ……DEFENDANTS
3. GLOBAL WEST VESSEL SPECALIST LTD
4. ODIMIRI ELECTRICALS LTD
5. KIME ENGOZU
6. BOLOBOERE
PROPERTY AND ESTATE LTD
7. REX ELEM
8. DESTRE CONSULT LTD
9. GREGORY MBONU
10. CAPTAIN WARREDI ENISUOH
AFFIDAVIT IN SUPPORT
OF MOTION EXPARTE
I, Adah
John Adah, Male, Christian, Nigeria citizen, litigation officer of Festus
Keyamo Chambers, 1, Festus Keyamo Lane, off Adebayo Mokuolu Street, off Gbagada
Expressway behind Newcastle Hotel Anthony, Village do hereby make oath and
state as follows:
1.
That
I am a litigation officer in Festus Keyamo Chambers, whose principal is Festus
Keyamo, Prosecuting Counsel to the Complainant/Applicant in this suit, by
virtue of which I am conversant with the facts of this case.
2.
That
I have the consent and authority of the Complainant/Applicant to depose to this
affidavit.
3.
That
I was informed by Festus Keyamo, Esq. and Idris Adamu, Investigating Officer
attached to Economic and Financial Crimes Commission, in our office on 17th
of February 2016 at about 2.00pm and I verily believe him as follows:
i.
That
the 1st Accused person was invited by the complainant on several
occasions to come and answer to the allegation of fraudulent activities leveled
against him which was uncovered during investigation.
ii.
That
the 1st Accused person was charged before this Honourable court to
answer to charges leveled against him when he persistently refused and failed
to honour the several invitations extended to him.
iii.
That
this honourable court also made an order dated the 12th day of
January, 2016 for the service of the said Charge and Summons to compel the
attendance of the 1st Accused
person on the 14th day of January, 2016.
iv.
That
upon becoming aware of the pendency of this proceeding, the 1st
Accused person instructed the law Firms of Messrs. Tayo Oyetibo & Co. and
Messrs. Ebun-Olu Adegboruwa & Co. to represent him.
v.
That
as a result of paragraph iv above, Messrs. Ebun-Olu Adegboruwa & Co.
applied for and obtained copies of the processes filed by the
Complainant/Applicant which led to the issuance of a Warrant of Arrest.
vi.
That
on the 14th day of January, 2016 this Honourable Court issued a
Warrant of Arrest for the 1st Accused person.
vii.
That
since the issuance of the warrant of arrest, the 1st Accused person
has absconded and concealed himself from all security forces in the country to
frustrate the execution of the Warrant of Arrest.
viii.
That
rather than present himself to the court, the 1st Accused person engaged
the services of Tayo Oyetibo, SAN who filed a Motion dated 27th day
of January, 2016 to set aside the Warrant of Arrest. The said motion was
dismissed on the 8th day of February, 2016.
ix.
That
since the Order for the arrest of the 1st Accused person, the
combined team of the Nigerian police and the military have been combing the
creeks and the entire nation for the arrest of the 1st Accused
person, but he continues to abscond and conceal himself.
x.
That
operatives of the Complainant have carried out investigation and received intelligence
report to the effect that the following properties belong to the 1st
Accused person:
a.
Property
at No. 1 Chief Agbamu Close DDPA Extension Warri (Effurun), Delta State.
b.
All
properties of Mieka Dive Ltd and Mieka Dive Training Institute Ltd situated at
No. 77, Lioth Street, ODPA Ugborikoko, Uvwie Local Government Area, Delta
State.
c.
All
properties of Global West Vessel Specialist Ltd.
d.
All
properties of Muhaabix Global Services Ltd
e.
A
River Crew Change Boat named MUHA – 15
f.
The
property known as “Tompolo Dockyard”, by the end of Enerhen Road, Effurun,
Warri.
g.
The
property known as “Tompolo Yard”, at the end of Chevron Clinic Road, next to
Next Oil, Edjeba, Warri.
h.
The
Diving School at Kurutie, at Escravos River.
i.
The
property known as “Tompolo House” at Oporaza Town opposite the Palace.
j.
Any
other property discovered by the Economic And Financial Crime Commission,
moveable and immoveable, belonging to the 1st Accused person.
4.
That
it is in the interest of justice to grant this application.
5.
That
I make this affidavit in good faith knowing and believing the facts deposed
herein to be true and in accordance with the oath Act of Nigeria.
………………………………
DEPONENT
Sworn
to at the Federal High Court Registry, Lagos
This
18th day of February, 2016
BEFORE
ME
COMMISSIONER
FOR OATHS
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