Multimedia's complete defense to the government's complaint to the CNS on the militia documentary

General News on Friday, April 19th, 2019

Source: www.Ghanaweb.com

2019-04-19

Following the government's petition against Joy News's "Militia Documentary" to the National Media Commission (NMC) requesting a retraction order and an apology, the Multimedia Group Limited reacted at length.

The documentary is an infiltration work of Manbadeh Azure Awuni titled "The Militia in the Heart of the City" shows a group of young men and women who would belong to a private security company or militia group, the De-Eye Group , during one gathered at Christiansburg Castle in Osu, the former seat of government.

In operation for two years, Manbadeh found that the group had already ensured the security of a number of party functions in which the president had taken part.

One of the leaders of the group, Nana Wireko Addo, in the infiltration work that followed one of these functions, conveyed the warm impressions of President Akufo-Addo to the group when he badured the security of an event organized at the International Conference Center in 2018.

But the government insisted that the content of this documentary was "misleading" and then petitioned the NMC.

"In accordance with Article 15 of Law 449, the Government is demanding a declaration that the contested documentary by Manbadeh Awuni Azure and Joynews is misleading and constitutes a dishonest and deliberate misrepresentation, supposed to cause apprehension, alarm and an unjustified panic to the public, "parts of the petition signed by the Minister of Information, Kojo Oppong Nkrumah, read.

"We sincerely hope that this complaint will be the subject of a serious investigation by the Commission in accordance with the journalistic standards published by the Commission and the ethics of the media profession," added the press release.

In the petition dated March 13, 2019, the government further stated: "We view the disputed documentary as part of the boundless slander of Manbadeh Awuni Azure, Joynews and its affiliates, which aimed to distort government policy and to deal with issues of national interest such as combating vigilance ".

"Just as the undisputed antecedents of the president show a selfless dedication to the defense of press freedom and human rights, irresponsible and unethical journalism threatens democracy and peace in the country. . "

Below, the complete answer from Multemedia

TO THE ESTABLISHMENT COMMITTEE OF THE NATIONAL MEDIA COMMISSION – NMC

ACCRA – J.D. 2019

IN THE MATTER OF PART III OF THE NATIONAL MEDIA COMMISSION ACT, 1993 (AN ACT NO. 449) AND THE NATIONAL MEDIA COMMISSION'S 1994 REGULATIONS (COMPLAINT AND COMPLAINT PROCEDURE) (LI 1587)

-And –

IN THE CASE OF A COMPLAINT FROM THE GOVERNMENT OF GHANA AGAINST MULTIMEDIA GROUP LIMITED

ENTER

GOVERNMENT OF GHANA – COMPLAINANT

AND

MULTIMEDIA GROUP LIMITED – RESPONDING

————————————–

RESPONDENT'S RESPONSE TO THE COMPLAINT

UNDER R4 (2) NMC LI 1587, 1994

————————————–

The interested party, located at 355 Faanofa Street, Kokomlemle, Accra, expressly disputes each of the allegations contained in the complaint dated March 13, 2019, as if they were exhibited in extenso and crossed in series, and as follows:

The defendant informs the hearing that he must, at the hearing of this complaint, raise a preliminary legal objection to the complainant's ability and / or ability, in law, to lodge a complaint. and to seek compensation, as well as a probable right within the meaning of Article 162 (6) of the 1992 Constitution.

This clarification of the specific ability or complainant may be necessary, the defendant's reading of the first paragraph / (ii) relief of the complaint appears to create potential confusion in this regard, and read against your cover letter. In any event, the respondent must comply with the purported capacity mentioned in the said first paragraph / adjustment (ii) to designate the Government of the Republic of Ghana.

Again, the party (s) against whom the complaint is made is not exactly apparent as it should be in the face of the complaint – it is against a specific unit of Multimedia Group Limited . In this case too, the defendant will rely on the plaintiff's reference to "JOY NEWS" (on the face / content of the complaint and the letter of support from the Commission, as well as from the complainant). other references to units and "various affiliates") and prefer to treat it under the umbrella Multimedia Group Limited in the spirit of fully badisting the Commission.

That, despite subsections (2) and (3) above regarding the lack of a correct and unambiguous identification of the parties or the complainant's ability, essential element to meet in particular the fundamental legal requirements, in particular with respect to the merits of the complaint, please be badured, as always, of the Respondent's commitment to badist the Commission in this case to achieve the objectives of procedural and substantive justice, in the full respect for the law and the Constitution.

That, in turn, the respondent begin his answer by observing the following by judicial notice:

This defendant is incorporated under the laws of Ghana with the following business units: Joy FM, Adom FM, Asempa FM, Nhyira FM, Luv FM, Hitz FM, MultiTv (with channels including JoyNews), Myjoyonline.com and Adomonline.com arguably the largest number of stories from any media in Ghana.

This defendant is Ghana's leading private commercial establishment in the mbad media, which operates the said media channel in the service of Ghanaian citizens for the effective exercise of their fundamental rights to freedom of speech and expression guaranteed by the Constitution, which includes the freedom of the press and other media in respect of the law and journalistic ethics.

That in the performance of their work and their profession, staff attend the invitation of state and non-state agencies and actors to provide radio, television and online coverage. News critical for later dissemination to Ghanaians in their homes, offices etc. in their different cities, villages and hamlets, and around the world.

In addition to the previous sub-paragraph, the defendant receives distress calls and draws the attention of concerned agencies, including the police and fire departments, to acts that threaten the peace of a community or country in order to that prompt measures be taken to prevent damage to life and destruction, property among others.

The respondent, in accordance with the preceding subparagraphs, conducts research and surveys on various issues of community and national interest, including latency or onset of illness, helps to raise public awareness and educates individuals to avoid contracting diseases, etc.

The defendant, in accordance with the preceding paragraphs, duly empowered, including in accordance with Chapters 5, 6 and 12 of the Constitution, has complied with its constitutional obligations, in particular Article 41 (f), to denounce and fight corruption to promote ideals, as provided for in Chapter 6 of the Constitution.

In fact, the current broadcast on the respondent group's network is a documentary of such importance, of paramount importance to the country, which touches the very heart of citizenship. It is nicknamed "The citizens of paper" – it is expected that Parliament will act even as the competent authorities arrest and prosecute officers and scammers in the register of births and deaths.

The respondent has produced innumerable documentaries that have prompted the state to act, including recent ones aimed at improving the conditions of detention in prisons under Chief Justice Georgina Wood, to combat threat posed by the ground guards and Galamsey, and with the public support and enlightened leadership of The First Lady Rebecca Akufo Addo provides vital health facilities that build one from scratch, now used by mothers and babies.

Normally, the defendant also attempts to denounce human rights violations, poor health conditions, poor education, poor shelter, among others, in particularly disadvantaged communities and less privileged people, in order to seek support / redress from public and private agencies, including: philanthropists, all of whom contribute significantly to improving the overall well-being of society.

The respondent through its various outlets projects and celebrates the country, or institutions and individuals doing patriotic acts and other positive and inspiring acts, and raises funds to support bright but needy students, build schools, provide furniture, libraries, drilling and other essential needs as appropriate. are missing.

This respondent pursues television programs respecting professional ethics and strives at all times to play the role of leader in its various forms of media operations.

This defendant has neither the motivation nor the desire to act or promote content that is "… shocking, totally false, produces gross misrepresentations of wild facts and speculations …", as the complainant claims.

That a civil action bearing the same subject before the CNG under the number GJ936 / 19 is pending before the High Court of the division of the general jurisdiction in Accra, although qualified by the De-Eye Group Limited as a crime of defamation , subject of the documentary in question.

Further to paragraph (1) above and in accordance with this constitutional decree, the defendant has duly fulfilled the constitutional obligation by publishing the complainant's rejoinder, granting him a deserving place and referring to it at all times when he has treated the object in the present. flagship programs. Attached, the reply is molded into the complaint mold, marked "1" and the Respondent's proof of publication Exhibit "1A".

The respondent argues from the outset that the reference and use of the words "militia" and "safe area", which form the basis of his complaint or charge, is the opinion of the Respondent and his loyal comment in fact and in law on the subject. its investigations and not subject to the contrary opinion of the complainant (or the Commission) as such will be contrary to the code of ethics in journalism, the code of ethics of the GJA, would aim to amend the law in defense of justification / opinion / comment, and even more dangerously, in Article 21 of the Constitution, to impede the constitutional and fundamental rights of the individual / media to the freedom of expression.

Further to paragraph (7) above, the Respondent has dwelt on facts including the official extension of the word "militia" by a constitutional commission set up by HE the President of the Republic of Ghana to investigate cases. concerning the electoral violence alleged to have been raised in part. from what many people in the public have so far called the "political party vigilante".

In fact, in the said documentary, the group in question is referred to indifferently as "vigilante" and "militia" and this second usage appeared because, during the production of the documentary, a member of the Ayawaso West Inquiry Commission Wuogon By Election Violence, Professor Henrietta Mensah-Bonsu, observed and emphasized as follows:

"We call it political vigilantes and we do not really appreciate how much it is, it's the warlord, they're militias, they're not political militia, they're militias. private militias, under the control of certain people, these people are warlords.

This introduction (of the said militia) was presented not only by a member of the said commission, but also by one of Ghana's most prominent criminal law professors, with international visibility and experience of the issue, having been member of the 14 high-level members of the UN Secretary-General. Independent Panel on Peace Operations, Deputy Special Representative of the Secretary-General for the Rule of Law at the United Nations Mission in Liberia (UNMIL), worked for the United Nations Organization for African Union (OAU), the African Union and the Economic Community of West African States (ECOWAS), Ghana's representative to the Intergovernmental Committee of Experts on the Drafting of the African Charter on the Rights and Welfare of the African Child in 1991, and the Committee of Experts on the OAU Affair on the Lockerbie Affair, member of the group International Bar Association Association for the drafting of a code of professional conduct for defense counsel appearing before the International Criminal Court to which it was preferred Dacy of judgeship.

The respondent was not surprised by the fact that the Chair of the Commission, also reputed and expert in the matter, challenged its use, as well as the other member of the Commission, former Inspector General of the Police Service from Ghana. In fact, internationally renowned security experts shared the usage that led to widespread acceptance, replacing the common use of the political party activist.

That the word "militia" is thus used and understood in its context does not mean to be identical to what the first technical meaning might find in a dictionary, but rather vaguely along the second non-technical sense of the definition such as in Wikipedia, is essentially a "combat organization composed of lay soldiers, citizens of a country or subjects of a state".
The respondent must rely on the defense of just cause, privilege, fair comment / opinion and the public interest for the following facts:

PARTICULARITIES OF JUSTIFICATION / PRIVILEGE

COMMENT / OPINION FAIR

PUBLIC INTEREST

The defendant's investigation of the De-Eye group between October 2018 and March 2019 is a fact.

The investigations were triggered by information that the group was participating in military exercises and security training for the youth of Osu Castle, which was confirmed by the investigations. Conduct of military training by a private group is illegal and punishable by imprisonment.

That the group is a militant militant group affiliated to the NPP created in 2009 is a fact and a report in the Daily Guide of June 2012 with a photo entitled "The Vigilante Group promises to protect the ballot boxes" refers to the group: "Trained in In 2009, "Eye Vigilante" is made up of male and female members of dynamic nuclear power plants across the country, whose main goal is to protect members of nuclear power plants from attacks by lawless people. Exhibit "2" is attached to this letter.

That a report on UTV also qualifies the vigilante group group and that a popular member of the NPP from the Ashanti region, who is also a senior officer of a polling station in Moshie Zongo in Kumasi, publicly named Alhaji Haruna Mohammed, the group as one of the self-defense groups of the nuclear power plant. It is instructive to note that he granted this interview as a spokesperson for the well-known invisible forces. Exhibits "3" and "3A" are attached.

Contrary to the statement that the group is an informal badociation of young people looking for a job, its meetings are characterized by training and speeches describing a security group within the nuclear power plant. Members have never been captured to receive instructions on interview techniques or resume writing.

That the investigations have captured members of the group in meetings responding to the motto of the group "Vigilance and Protection".

That the leader of the group is called "commander", while the second in command is called "chief of staff".

Whether the group applauds or applauds in the familiar military style "Ahooo! Ahoyaha!

That the trainers of the members of the group are former army officers is not the subject of any controversy, even from the group itself.

That the group's official website, which was clandestinely deleted after its activities were revealed by the Respondent, is posted on the About Us page: "The DE-EYE Group was designed to meet the growing need for more efficient jobs and more efficient security services. in Ghana. It belongs 100% to Ghanaians, is registered and registered. All of our staff are experienced and well trained by retired officers. They are very reliable. Our staff also undergoes rigorous controls, checks criminal histories, and verifies the presence of drugs in the criminal record. The attached Exhibit 4 is attached to this letter.

The fact that the investigations revealed that the Ministry of the Interior authorized to accredit private security companies and to regulate it had not authorized the De-Eye group, is a fact and the same behavior is contrary to the law. This behavior, including mere membership in such an entity, is punishable by fines and jail time. You will find attached Exhibit "5".

Investigations revealed that the group had ensured the security of a high-level event in a nuclear power plant, in honor of Chief SD Dombo, with the president, the vice president and his wife, the Former President John Agyekum Kufuor, along with other prominent NPP members present at the Accra International Conference Center on December 7, 2018 is a fact.

In 2018, Fraser Owireku Kegya, the group's chief of staff, told TV3 in an interview that the group had more than 5,000 young people "across the country" who believe in the policies of President Nana Addo Dankwa Akufo-Addo, and at the end-of-year meeting held at the castle, the opening prayer indicated that they had come together as "family of nuclear power plant" Is a fact.

The fact that the group illegally chased National Security agents stationed at the Aviance Cargo Village of Kotoka International Airport in Accra in 2017 and deployed its members in replacement is a fact.
That it took a director of the National Security Secretariat to conduct another operation to reverse this criminal act and send the national security agents back to their legal operational zone is a fact.

That on December 10, 2018, Fraser Owuireku Kegya told the group at the castle that they had become a priority whenever senior security officials in Ghana met is a fact.

On December 17, 2018, the group's commander, Nana Owireku Addo, told members that national security had attempted to destroy the group but had failed and sent spies to find evidence against them, and that it was had asked to be vigilant and to reveal infiltrating National Security members their camp are a fact.

On December 10, 2018, Fraser Owireku Kegya lamented the pace at which members of the group were often involved in criminal activities and breaking the law, and warned that if someone did an unauthorized operation and was arrested again it would allow that person to be in the police cells for a while and then be brought to dishonor them in the presence of the group, that is a fact.

On December 17, 2018, one of the trainers started the meeting of the day by praising its members that none of them had been arrested this weekend was a fact.

This defendant verified the facts and also contacted the group and gave him a chance to respond to investigations. Twice the scheduled meetings have been canceled by the group. Respondent 's staff spoke with the group on February 22, 2019 and a meeting was arranged for February 26, 2019. On that date, the Respondent' s staff went to the Roman House. Ridge School and called the group leader to ask him for additional instructions. . The respondent's staff made more than 10 phone calls that went unanswered even though, in some cases, it indicated "busy number". Respondent's staff sent the following message: "Good evening, sir.

This is Manbadeh Azure Awuni from Joy FM. I am in Roman Ridge. I need a direction to your office. After more than 20 minutes of waiting, the Respondent staff left and sent the following message on WhatsApp: "Good evening, sir. I called several times tonight but you did not answer. I was at Roman Ridge. I produced a documentary on political activism and learned that you had a group of militiamen. The meeting is meant to hear you because it's just that if I make a story about you, I get your story version. Please, let me know when it will be easy for us to meet each other. Have a good evening. The WhatsApp message was checked in blue, indicating that it had been read, but there was no answer.

On March 1, 2019, the Respondent's staff placed an appeal and another meeting was duly organized. The respondent's staff went to Roman Ridge School and asked for further instructions, as mutually agreed, but the appeals went unanswered. He sent this message via SMS and WhatsApp: "Hello, sir. I am here at Roman Ridge School. I've called several times but you do not answer. The message was sent, but there was no response. After more than 30 minutes of appeal, the respondent's staff left.

On March 5, 2019, the Respondent's staff sent another WhatsApp message: "Hello, sir. We are going ahead with the story I told you about. If you still want to answer or if you have something to say, thank you for letting me know. Thank you so much. "The message has been delivered. He checked blue, but did not answer.

That at the two above-mentioned meetings, the Respondent's staff consisted of two people each time and together.
That, as it is duly recognized in the documentary, the defendant, in addition to dealing with reliable sources within the group itself, was dealing with state security sources and sources also asked the presidency whether she knew the group and its activities and whether it received a negative response, and that evidence of telephone conversation may be available at the request of the Commission, including those allowing exclusive viewing restricted to strictly confidential non-disclosure conditions.

During the course of his audit, the respondent engaged a number of the complainant's ministers, including asking the communications director of the Office of the President, the Minister of Information, the author and the signatory of the complaint. The various telephone interactions, including off-register, with said agents of the State can be disclosed to this Commission only with the express consent of these parties, in strict compliance with the law.

This question from the defendant to Mr. Arhin was therefore the following: "Good evening. I called earlier. I'm reporting on De-Eye Group, a militant NPP group led by Nana Wireko Addo, aka Choman, former bodyguard of President Akufo-Addo. I have information that the group operates from the castle of Christianbourg. Some group leaders say the president is aware of their operations in this country. I spoke to a source close to Jubilee House, close to the president, who denied the presence of the group at the castle and the knowledge of the president, but this is not the official answer, according to the source. I will be happy to have the official answer on this subject by tomorrow. "

This is what Mr. Arhin responded: "The President is not aware of the alleged activities of this group, let alone punish them. My national security checks revealed that no group of this type operates from the castle.

That the group operates an office in the castle is a fact. Refer to the complainant's confirmation in Exhibit "1".
That the leader of the group is a former H.E. bodyguard the president is a fact as noted in the documentary. Refer to the complainant's confirmation in Exhibit "1".

The group was deported by a joint task force of police and national security after meeting at the castle and operating in an office. Refer to Exhibit "1".

This defendant also took note of the statement of the State Security Minister, Bryan Acheampong, of Sunday, March 10, 2019, that the security apparatus was "aware that Nana Wireko, aka Choman , had founded his company The Castle Secretariat, where we warned him twice and stopped, threw him out of the office and closed it in October at our third meeting with him. You will find attached Exhibit "6".

The fact that the castle at the time of the events constituted a safe area is a fact for reasons, inter alia, that security agents have confirmed, including allowing only a restricted entry or qualified , banning activities / activities such as journalists shooting videos.
Following the previous paragraph, Joseph Ackah Blay of the respondent, who covered the said meetings of the Commission at the castle, had twice attempted to report live from that location and had not been able to do it inside or outside the castle. Security told him that it was a security zone and that his camera was not allowed anywhere but inside the room where the cameras were being held. debates.

Further to the previous subparagraph, Dr. Kwesi Aning of the International Peace Training Center Kofi Annan was prevented by security from entering the castle when he was invited to appear before the said Commission. In an interview, NewsFile, one of the world's leading security experts, told the respondent that it was a security zone and that his car had no security clearance. Exhibit "7" is attached hereto.

In addition to the previous sub-paragraph, the castle was known as an annex to the government headquarters housing up to four ministers' ministries in the president's office.

That said, the castle still houses a fuel service station specifically for the offices / officers of the state.

During his appearance before the Commission, the State Minister for National Security, Bryan Acheampong, referred to people dressed in black and white at the castle and called them National Security Officers. . The defendant has a different point of view and has the same right that the national security officers are not in uniform. These people were obviously members of the De-Eye group.

That the complaint concerning the defendant's use of a file photo for online publication, as presented by the complainant, merely betrays mischief or ignorance of the practice of journalism. The respondent produced a television commercial for the documentary, which was in any case a television documentary. The use of an "archive photo" for its online publication is an authorized practice and does not violate any rule or law in journalism. The file photo used for the online publication was accompanied by the inscription "Photo File" and therefore should not mislead readers. A copy is attached and marked with "8".

The complainant should not have the right to complain about the aforementioned documentary and to point out in particular what he claims to be a deliberate omission of the "important fact" of an alleged date of closure of the group office at the castle after ignoring the opportunity offered to him. for reactions before diffusion. The respondent was entitled to transcribe as far as possible the facts gathered, including the plaintiff 's categorical denial of the group' s knowledge of the castle when the respondent had offered him his chance.

Le défendeur soutiendra que la réclamation tardive / ex post facto du plaignant d’un «fait important» ne peut être qu’un fait ou un fait de nature importante connu du plaignant uniquement. En tout état de cause, l'affirmation du plaignant selon laquelle les activités du groupe au château cesseraient d'ici octobre 2018 ne peut être que fausse, du moins pour l'intimé, car l'intimé a prouvé la preuve oculaire du contraire, y compris ce qui est précisé aux présentes à l'alinéa ( L) du paragraphe 13. Les images complètes de l'enquête sont mises à la disposition de la Commission sur demande.

La plainte concernant le contenu des six premières minutes du documentaire est une tentative la plus fallacieuse de dicter et de discrétion directe dans une censure astucieuse et elle doit être rejetée d'emblée. Le contenu en question était très pertinent et d'intérêt public.

L'intimé soutient que les faits reprochés sont des sujets de grand intérêt pour le public dans son ensemble et pour ses dirigeants, au point que H.E. le président met en place une commission constitutionnelle, enjoignant aux chefs de partis politiques de s'employer à mettre fin au phénomène et chargeant le procureur général de soumettre un projet de loi à cette fin.

Dans les locaux de l'alinéa précédent, le défendeur et le public avaient un intérêt correspondant ou commun à ce sujet, et lesdites émissions / publications du documentaire étaient diffusées conformément au devoir imposé par la Constitution aux médias et aux citoyens en général .

L'intimé soutient que le plaignant n'a droit à aucun des redressements demandés et que la présente plainte est sans fondement, illégale et
action inconstitutionnelle principalement destinée à:
entrave et frustration, de manière inconstitutionnelle et licite, du défendeur et des médias dans l'exercice du devoir et de l'obligation qui leur sont imposés ainsi qu'aux citoyens, aux termes de l'alinéa f) de l'article 41 de la Constitution: «Protéger et préserver les biens publics et exposer et combattre les utilisations abusives et le gaspillage des fonds et des biens publics ";

entrave et frustration inconstitutionnelle et illégale du défendeur et des médias dans l'exercice des droits à la parole et aux médias garantis par l'article 21 de la Constitution;

d'inconstitutionnaliser et d'illégale violation du droit des citoyens à l'information garanti par l'article 21 f) de la Constitution, en particulier pour les questions d'intérêt public.

contraires à la Constitution et illégalement à la censure et à porter atteinte à la liberté et à l'indépendance du défendeur et des médias, en violation de l'article 162 (1) et (2) de la Constitution.

d'interdire et d'empêcher, de manière inconstitutionnelle et illégale, d'empêcher le défendeur d'exercer les privilèges garantis à l'article 162 (4) de la Constitution qui: [e]Les diffuseurs et les éditeurs de journaux et autres institutions des médias ne sont soumis ni au gouvernement ni à une ingérence, ni sanctionnés ni harcelés pour leurs opinions et points de vue éditoriaux, ni pour le contenu de leurs publications.

d'interdire et d'empêcher de manière inconstitutionnelle et illégale d'empêcher le défendeur d'exercer le lourd devoir imposé aux médias en vertu de l'article 162 (5) de la Constitution qui: [a]Tous les organes des médias sont libres de respecter les principes, les dispositions et les objectifs de la présente Constitution, ainsi que la responsabilité du gouvernement à l’égard du peuple ghanéen.

Le plaignant ne devrait pas être autorisé à imposer son ensemble de faits et interprétations à l'intimé, car cela semble être le sens de la plainte et rien de plus.

Le défendeur soutient qu’il n’a jamais commis d’inconduite professionnelle ni enfreint de règle, de code, de loi ou de la Constitution, et qu’il n’a certainement jamais accusé le plaignant d’avoir inclus un documentaire contenant des propos «offensants, totalement faux». , produit de la déformation grossière des faits et de la spéculation sauvage. "

Par conséquent, le plaignant n’a droit à aucun des redressements qu’il demande, et sa plainte étant sans fondement et non méritoire, elle devrait être rejetée sans suite, avec une ordonnance de rétractation et des excuses auprès de l’intimé pour avoir discrédité la réputation de l’intimé et de son personnel désigné, y compris dans ses fonctions. communiqué de presse et cette plainte largement diffusée.

Respondent shall also implore the Commission to ensure a full recording of its hearing of this Complaint and to render a reasoned decision dealing with each and every plaint of the Complaint vis a vis the heads/basis of each response in the Response.

DATED AT A-PARTNERS @ LAW, H/NO. 4, EASMON ST., OPP. THE TRUST CLINIC, NEAR CLUB 250, OFF THE MAIN ROUNDABOUT, DANSOMAN, ACCRA, THIS MONDAY, THE 27TH DAY OF MARCH, 2019.

SAMSON LARDY ANYENINI ESQ.
A-PARTNERS@LAW
SOLICITORS FOR RESPONDENT

THE AG. EXECUTIVE SECRETARY

NATIONAL MEDIA COMMISSION

ACCRA

AND FOR SERVICE ON THE COMPLAINANT VIA HON. KOJO OPPONG–NKRUMAH, MINISTER, MINISTRY OF INFORMATION, ACCRA.