Dery petitions Mahama over true identity of Tiger Eye PI

In a petition to the president, the lawyers said “Your Excellency, we have our client’s instructions to request that you cause an investigation to be conducted into the true identity of the petitioner, since from the evidence adduced herein, the petitioner Tiger Eye PI who purported to file a petition with your office is non-existent.”

“Your Excellency, our client has caused us to file various searches at the relevant statutory institutions to determine the identity of the petitioner, Tiger Eye PI. We must state at this point that the revelations from the searches appear to show that there is no company in Ghana by the name Tiger Eye PI and we would proceed to demonstrate same by taking the search reports one after the other," the petition added.

Below is the full petition

8th February, 2016THE PRESIDENT OF THEREPUBLIC OF GHANAFLAGSTAFF HOUSEACCRADear Sir,RE: PETITION OF TIGER EYE PI FOR THE REMOVAL OF JUSTICE PAUL UUTER DERY – A FORMAL COMPLAINT1. Your Excellency, we have the instructions of our client Justice Paul Uuter Dery to file this formal complaint to you for your necessary action.2. Your Excellency, sometime in September, 2015, our client was summoned to the office of Her Ladyship the Chief Justice where a letter was handed over to him. Upon perusal of the said letter, our client realized that a company by name Tiger Eye PI had petitioned you for his removal from office as a Justice of the Superior Court pursuant to Article 146 of the 1992 Constitution. The letter further indicated that you had forwarded the said petition to Her Ladyship the Chief Justice to determine whether or not there is a prima facie case against our client pursuant to Article 146(3) of the 1992 Constitution.3. Your Excellency, our client has caused us to file various searches at the relevant statutory institutions to determine the identity of the petitioner, Tiger Eye PI. We must state at this point that the revelations from the searches appear to show that there is no company in Ghana by the name Tiger Eye PI and we would proceed to demonstrate same by taking the search reports one after the other.a. SEARCH FROM THE REGISTRAR GENERAL’S DEPARTMENTYour Excellency, the search report from the Registrar of Companies of Ghana, who is the legitimate statutory body who registers companies limited by shares, on its search report dated 3rd November, 2015 significantly states thus:“We do not have any company on record called TIGER EYE PI. We have on record TIGER EYE PI MEDIA LIMITED”.(Please find attached and marked as “PUD 1”, a copy of the search report from the Registrar-General).b. SEARCH FROM SOCIAL SECURITY AND NATIONAL INSURANCE TRUST (SSNIT)Your Excellency, the petitioner had occasions to appear in court and there, since it is a legal person, it is represented. It has always been represented by persons who inform the court that they are employees of the petitioner company. By law therefore, the petitioner must register with SSNIT and pay the social security contributions of its employees. This prompted us to file a search with SSNIT and this is what the report says:“SEARCH: TIGER EYE PI MEDIA LIMITED/TIGER EYE PIWe acknowledge receipt of your letter and wish to inform you that the name in our records is Tiger Eye Consult Limited. The said establishment was registered with SSNIT on the 13th of June, 2013”.(Please find attached and marked as “PUD 2”, a copy of the report from SSNIT).c. SEARCH REPORT FROM MINISTRY OF INTERIORYour Excellency, the petitioner claims to be a Private Security Organization licensed by the Ministry of Interior pursuant to the Police Service (Private Security Organizations) Instrument, 1992 (L.I.1571) to carry out its operations. We therefore filed a search with the Ministry of Interior and this is what the report says:“Records available in this Ministry indicate that Tiger Eye PI Media Limited was licensed as a Private Security Company by this Ministry in 2010 but later the name was changed to Stallion Tiger Limited in 2012”.(Please find attached and marked as “PUD 3”, a copy of the search report from Ministry of Interior).d. INFORMAL SEARCH FROM REGISTRAR-GENERAL’S DEPARTMENTYour Excellency, throughout all the happenings in respect of the petition of Tiger Eye PI, we have never heard of Stallion Tiger Limited. Since the regulator of Private Security Organizations, that is the Ministry of Interior has come out with a company by name Stallion Tiger Limited, we became curious and did an informal search online about Stallion Tiger Limited. The report we had indicated that indeed Stallion Tiger Limited was incorporated on 12th September, 2012. (Please find attached and marked as “PUD 4”, a copy of the informal search).4. Your Excellency, it is on record that the Chief Executive Officer of Tiger Eye PI is one Anas Aremeyaw Anas. It is also on record that Anas Aremeyaw Anas is one of the two Directors of Tiger Eye PI Media Limited and the sole shareholder. He is also one of the two Directors of Stallion Tiger Company Limited and the sole shareholder.5. Your Excellency, events and statements after the filing of the petition for the removal of our client as a Justice of the Superior Court indicates that there is confusion as to the true identity of the petitioner. On the face of the petition, the petitioner is Tiger Eye PI. However, statements put on social media by the Chief Executive Officer of Tiger Eye PI, Anas Aremeyaw Anas, and the company lawyer, Mr. Kissi Agyebeng indicate otherwise.6. Your Excellency, the petitioner, Tiger Eye PI, through its Chief Executive Officer, Anas Aremeyaw Anas put on the petitioner’s facebook page on November, 11, 2015, the following information. The headline speaks for itself. It states thus:“TIGER EYE PI LTD REACTS TO MARTIN AMIDU’S ABYSMAL FAILURE TO PROVIDE EVIDENCE TO SUPPORT HIS ALLEGATIONS”.7. In the body of the above article, Anas Aremeyaw Anas, speaking for the petitioner Tiger Eye PI, states among others as follows:“Mr. Amidu is right in one, and only one respect: a company limited by shares, such as we are, is required to state its name with the suffix ‘Limited’ or ‘Ltd’….Mr. Amidu, if we are guilty of anything, it is that we have sometimes neglected to add that suffix to our name ….”. (Please find attached and marked as “PUD 5”, a copy of the said article on the petitioner’s facebook page).8. Your Excellency, what the petitioner is now saying is that its proper identity is “Tiger Eye PI Ltd”. Indeed the statement was issued and signed by Anas Aremeyaw Anas, C.E.O of Tiger Eye PI Ltd.9. Your Excellency, this change of identity again does not end the identity problems of the petitioner. Kissi Agyebeng, the lawyer for the petitioner also stated in an interview with Joy FM (an Accra Radio Station) and which was reported online thus:“Tiger Eye PI is a registered company. The mere fact that my client for the purposes of convenience chooses to write the name as Tiger Eye PI and not Tiger Eye PI Media Limited does not detract from the fact that it is the same entity”.(Please find attached and marked as “PUD 6”, a copy of the said statement).10. Your Excellency, from all the above the identity of the petitioner is put in issue. Graphically it looks like this:It started as Tiger Eye PI,To Tiger Eye PI LtdTo Tiger Eye PI Media LimitedTo Stallion Tiger Limited11. So your Excellency, if one is asked what the identity of the petitioner is, the answer would be problematic. Is the petitioner Tiger Eye PI as appears on the petition? Is it Tiger Eye PI Ltd or Tiger Eye PI Media Limited or Stallion Tiger Limited?12. Your Excellency, we have the instructions of our client to draw your attention to these serious identity problems of the petitioner for in our view, the identity of the petitioner is paramount to any petition for the removal of Justices of the Superior Court pursuant to Article 146 of the 1992 Constitution. References are hereby made to the Supreme Court decisions in Agyei Twum v. Attorney-General & Akwetey [2005-2006] SCGLR 637; and the Republic v. High Court (Fast Track Division), Accra; Ex parte Commission on Human Rights and Administrative Justice (Richard Anane – Interested Party) [2007-2008] SCGLR 213.13. Your Excellency, we have our client’s instructions to request that you cause an investigation to be conducted into the true identity of the petitioner since from the evidence adduced herein, the petitioner Tiger Eye PI who purported to file a petition with your office is non-existent.Yours faithfully,Addo, Addo Legal AttorneysNii Kpakpo Samoa Addo (Esq.)Cc: Her Ladyship The Chief JusticeHis Lordship Justice Paul Uuter Dery