DGEMUE AI 2 © FORM 1A AMCON PROCEEDINGS GENERAL CLAIM FORM q L IRT_NE IN THE LAGOS JUDICIAL DIVISION HOLDEN AT LAGOS SUIT NO, FHC/L/AMC/22/2022 BETWEEN: f ASSET MANAGEMENT CORPORATION - CLAIMANT OF NIGERIA AND 1 DEMAYO HOLDINGS (NIGERIA) LIMITED 2 MOSHOOD ADEMOLA OMIDIRAN 3 WULAYAT MOTUNRAYO OMIDIRAN DEFENDANTS 4 ABDULMALIK ADEDAYO OMIDIRAN GENERAL CLAIM FORM 1A - ORDER 3-4 (1)(d)(IT) 1. This Court commands you to file a Memorandum of Appearance in this Claim within Five (5) days of your receipt of this Claim. 2. If you fail to file a Memorandum of Appearance, the Clalmant may Proceed with Its claim and judgment may be given in your absence. 3. This action Is to recover the outstanding indebtedness of the Defendants to the Claimant arising from the various Facilities granted to the Defendants by Enterprise Bank Ltd (now Heritage Banking Company Ltd )(herein called “the Bank”) 4. The Defendants have defaulted in repayment of the Facilities which were duly acquired by the Claimant, 5. The Claimant claims against the Defendants as follows: @) The sum of 8319,658,903.56 (Three Hundred and Nineteen Million, Six Hundred and Fifty Eight Thousand, Nine Hundred and Three Naira, Fifty Six Kobo) being the outstanding2 indebtedness of the Defendants as at February 02, 2022 on which Interest continues to accrue. 'b) Interest at the rate of Fifteen percent (15%) per annum on the said sum of §319,658,903.56 (Three Hundred and Nineteen Million, Six Hundred and Fifty Eight Thousand, Nine Hundred and Three Naira, Fifty Six Kobo) from February 2, 2022, until judgment is delivered, ©) Interest at the rate of ten percent (10%) per annum on the judgment sum from the date of entry of final judgment in the suit until the said judgment sum Is fully and finally liquidated. d) An order directing the Defendants to pay the Claimant the cost of this action In the sum of N5,000,000.00. ) Accelerated hearing of this Suit for being su/ generis. ‘The Issuance of this Claim Form through its Legal Practitioner, C.O Eze Esq of MACMILTON LP, Akin Talwo & Co Consortium ,70A Itafaji Rad, Dolphin Estate, Tkoyi, Lagos, The Claimant's Legal Practitioner’s Contact Details are as follows: Name: C.0 EZE Esq. Law Firm: MACMILTON LP (Akin Taiwo & Co Consortium) Address: 70A, Itafaji Road, Dolphin Estate, Ikoyi, Lagos Phone Numbers: 07011637712, 08033265657 Email Address: [email protected],refi [email protected] SIGN CLAIMANT'S COUNSEL, DATE, (9) Information about Service | served this Claim Form on the Defendants on by at REGISTRAR3 INTHE FEDERAL HIGH Cou) IN THE LAGOS JUDICIAL DIVI! ae SUIT 1:0. FHC/L/AMC/22/2022 BETWEEN: ASSET MANAGEMENT CORPORATION - CLAIMANT OF NIGERIA AND 1 DEMAYO HOLDINGS (NIGERIA) LIMITED 2 MOSHOOD ADEMOLA OMIDIRAN 3 WULAYAT MOTUNRAYO OMIDIRAN DEFENDANTS 4 ABDULMALIK ADEDAYO OMIDIRAN ‘STATEMENT OF CLAIM 1, The Claimant is a statutory establishment of the Federal Government of Nigeria established pursuant to the Asset Management Corporation of Nigeria Act, 2010 (as Amended) ("the AMCON Act”) with its Head Office at 417 Tigris Crescent, Off Agulyi Ironsi Stret, Maitama, Abuja and vested with powers amongst others of efficiently resolving the non-performing loan assets of banks in Nigeria, assisting ciigible financial institutions to efficiently dispose of eligible bank assets and holding, managing and disposing of all such eligible bank assets, 2. The establishment of the Claimant was with a mandate to purchase the non-performing loan portfolio of commerci:! banks of Nigeria. One of such non-performing loan portfolio of commercis| banks is in the instant Suit Wherein the Claimant purchased the Deferiants unpaid loan facility from Enterprise Bank Ltd (now Heritage Banking Company Ltd )(herein called “the Bank"), 3. The email forwarding the computer print out of the documents Pleaded in this Suit is pleaded and shall be relied on at the trial. 4. The 1* Defendant was granted Loan Facilities by the Bank, The 1% Defendant was unable to repay the Facilities leading to the acquisition by4 the Claimant from’ the Bank as captured i" Loan Purchase Agreement dated 2012 is pleaded and shall be relied on at the trial, 5. Upon receipt of the Claimant's demand Letter dated 10" June 2020 hereby pleaded, the Defendants admitted debt anc! via a Letter dated 7" August, 2020 hereby pleaded, the Defendants offers: to pay the sum of N30Million in full and final but no further action to that ffect. 6. The Claimant wrote a Final Demand Letter to the Defendants hereby pleaded. 7. The 2% 3% and 4" Defendants are direc'-rs of the 1% Defendant. The Corporate Affairs Commission's particulars ' directors of 1% Defendant is hereby pleaded. 8. The amount owed by the Defendants to the Claimant stands in the sum of 8319,658,903.56 (Three Hunc ed and Nineteen Million, Six Hundred and Fifty Eight Thousanc’, Nine Hundred and Three Naira, Fifty Six Kobo) as at February 2, 2022 on which interest continues to accrue, The Defendant's Siatement of Account dated February 2, 2022 is hereby pleaded and shall be relied on at the trial. 9. The Claimant pleads and will rely at the ‘vial of relevant documents in proof of its claim bef his suit on any other this Honourable Court. 10. WHEREOF the Claimant claims against !/.e Defendants as follows: A) The sum of N319,658,903.56 (Thrce Hundred and Nineteen Million, Six Hundred and Fifty Eight Thousand, Nine Hundred and Three Naira, Fifty Six Kobo) bein. the outstanding indebtedness of the Defendants as at February 2, 2022 B) Interest at the rate of Fifteen percent-(15%) per annum on the said sum of 8319,658,903.56 (Three Hundred and Nineteen Million, Six Hundred and Fifty Eight Thousan:, Nine Hundred and Three Naira, Fifty Six Kobo) from February 02, 2022, until judgment is delivered. C) Interest at the rate of ten percent (10° ») per annum on the judgment sum from the date of entry of final judo:ent in the suit until the said judgment sum Is fully and finally liquidate: D) An order directing the Defendants to py the Claimant the cost of this action in the sum of N5,000,000.00.eneris, E) Accelerated hearing of this Suit for being su/ ¢ a7? ee 0, hiky Dated this é day of ah 2022 MACMILTON LP (Akin Taiwo & Co Consortium) CLAIMANT'S COUNSEL, No 70A Itafaji Road Dolphin Estate Ikoyi Lagos Email: amcong244 gmail.com refugedan@vahic o.com E 637712, 08033265657 FOR SERVICE ON THE DEFENDANTS. 11, Ajala Street, Osogbo, Osun. Tel:080330506066 INTHE FEDERAL HIGH CO! 27 NIGERIA IN THE LAGOS JUDICIA|. DIVISION HOLDEN AT LAGOS SUIT 9, FHC/L/AMC/22/2022 BETWEEN: ASSET MANAGEMENT CORPORATION - CLAIMANT OF NIGERIA AND 1 DEMAYO HOLDINGS (NIGERIA) LIMITED 2 MOSHOOD ADEMOLA OMIDIRAN 3 WULAYAT MOTUNRAYO OMIDIRAN DEFENDANTS 4 ABDULMALIK ADEDAYO OMIDIRAN LIST OF WITNESS( <5) The Claimant's Witness in this suit shall be David George v C. 0 Ete Esq & Dated this ...........day of 4 , 2022. MACMILTON LP (Akin Taiwo & Co Consortium) CLAIMANT'S COUNSEL No 70A Itafaji Road Dolphin Est.ite 1koy: Lagos Email: ame om, refugedait om : 07011637712, 08033265657 FOR SERVICE ON THE DEFENDANTS 11, Ajala Street, Osogbo, Osun. Tel:08033050606 E:[email protected]IN THE FEDERAL HIGH COURT NIGERIA INTHE LAGOS JUDICIA’ DIVISION HOLDEN AT LAGOS SUIT WO, FHC/L/AMC/22/2022 BETWEEN: ASSET MANAGEMENT CORPORATION - CLAIMANT OF NIGERIA AND 1 DEMAYO HOLDINGS (NIGERIA) LIMITED 2 MOSHOOD ADEMOLA OMIDIRAN 3 WULAYAT MOTUNRAYO OMIDIRAN DEFENDANTS 4 ABDULMALIK ADEDAYO OMIDIRAN WITNESS WRITTEN STATEMENT ON OATH. 1, David George, Male, Nigerian Citizen of 67, Marina, Lagos State do hereby make oath and state as follows: 1, That I am Credit Enforcement Gsficer in the employment of the CLAIMANT. 2, That by virtue of my position, I am familiar and conversant with the facts stated In this Witness Written Statement an Oath, 3. That the Claimant is a ‘statutory establishment of the Federal Government of Nigeria established pursuant to tne Asset Management Corporation of Nigeria Act, 2010 (as Amended) (“the AMCON Act”) with its Head Office at 417 Tigris Crescent, Off Aguiyi Ironsi Street, Maitama, Abuja and vested with powers amongst others of eificientiy resolving the non-performing loan assets of banks in Nigeria, assist! igible financial institutions to efficiently dispose of eligible bank assets and holding, managing and disposing of all such eligible bank assets. 4. That the establishment of the Clair with a mandate to purchase the non-performing loan portfolio of iclat banks of Nigeria. One of such non-performing loan portfolio of cortiniercial banks is in the instant Suit wherein the Claimant purchased the Oefendants unpaid loan facility from Enterprise Bank Ltd (now it Canking Company Ltd )(herein called “the Bank”).5. That the 1% Defendant was granted Loan Facilities by the Bank, The 1% Defendant was unable to repay the Facilities leading to the acquisition by the Claimant from the Bank as captured in Loan Purchase Agreement dated 2012 is attached as Exihibit. 6. That upon receipt of the Claimant's demai.d Letter dated 10" June 2020 hereby attached as Exihibit, the Defendants admitted debt and via a Letter dated 7 August, 2020, the Defendants offered to pay the sum of N3OMillion In full and final but no further ac\ion to that effect. rhe Letter is attached as Exihibit, 7. That the Claimant wrote a Final Demand Letter to the Defendants hereby attached as Exihibit. 8. That the 24,3 and 4" Defendants are directors of the 1° Defendant. The Corporate Affairs Commission's particulars of directors of 1% Defendant is attached as Exihibit. 9. That the amount owed by the Defer s to the Claimant stands in the sum of 8319,658,903.56 (Three Hundred and Nineteen Million, Six Hundred and Fifty Eight Thousar«, Nine Hundred and Three Naira, Fifty Six Kobo) as at February 2, 2022 on which interest continues to accrue, The Defendarit’s statement of Account dated February 2, 2022 is hereby attached as i:xibit. 10. That I depose to this Witness Staicment in utmost good faith verily believing all the depositions contained herein to be true and correct and in accordance with the Oaths Act 2 (ale Py ofa wa, 2022 - BEFORE Rog 2 vs \ COMMISSIO! i OATHS te A eSTN: INTHE FEDERAL HIGH COURT NIGERIA IN THE LAGOS JUDICIA|. DIVISION HOLDEN AT LAGOS SUIT 110, FHC/L/ANMC/22/2022 BETWEEN: ASSET MANAGEMENT CORPORATION - CLAIMANT OF NIGERIA AND 1 DEMAYO HOLDINGS (NIGERIA) LIMITED 2 MOSHOOD ADEMOLA OMIDIRAN w WULAYAT MOTUNRAYO OMIDIRAN DEFENDANTS + ABDULMALIK ADEDAYO OMIDIRAN LIST OF Docu: Print out email dated June 30, 2022 EX i tts, Print out Loan Repayment Agreement dated 2022 EX 2 Print out Demand Letter dated June 10, 2020 EX 3. Print out Defendant's Letter dated 7" August, 2020 EX 4, Print out demand Letter dated February 8, 2022 EX 5, Print out Corporate Affairs Commission Par ulars of the Defendants EX 6. Print out 1* Defendant’s Statement of Account dated February 02, 2022, EX 7, Dated this Oo day of ety 2022. xt VC. 0 Eze Esq MACMILTON LP (Akin Taiwo & Co Consortium) CLAIMANT'S COUNSEL el: 08063271821,08033265657 Nog soneFrom: Eke Vincent \ To: Chris Eze Sent: From: Eke Vincent ‘To: Chris Eze Sent: Thur, June 30 , 2022, 2:10:24 PM. Subject: REAMCON vs DEMAYO HOLDING & ORS= COURT ANNETURES Dear Chris Received with thanks. Vincent. Send from Yahoo Mail on Android On Thur, June 30 at 2.10pm, Eke Vincent wro From: Chris Eze To: Eke Vincent Sent: Thur, June 30, 1:30:24 PM GMT+1 Subject: AMCON vs DEMAYO HOLDING & OR: ANNETURES COURT Dear Mr. Eke, Please Find Attached, online corporate information of the Defendants, scan copy , copies of Amcon documents, Amcon Account Statements; Our demand. Letters, all on the above Obligor to enable you complete the printing of court Annexure and Exhibits in this Matter. Sincerely Yours, Chris Eze Esq.AMCO Asser MANAGEMENT ConPORATION OF NIG TERIA AND OE aay ENTERPRISE BANK LimiTep ‘aera LOAN PURCHASE AND LIMITED SERVICING AGREEMENT eeine me Otawiwun Asay boTauun OF Converts Definitions And Interpretation 1 2 2 Conveyance OF Loan Rights 6 \ 3 Consideration 8 4 Acknowledgment Of Good Faith 8 i 5 Cost And Expenses 9 ' 6 Post losing Deliveries And Delivery Of Further Decuments 9 4 7 Bank's Representations And Warranties 0 1 & Special Remedies 1 & 9 Comperation's Representations Aad Warranties 1s i 10. ‘Termination O€ Servicing By Bank Ane Tatorim Servicing Arrangements is f 11. Establishment Of Collestion Accounts And Deposits in Collection Accounts 8 H 12. vents OF Ded fn Respot OF Limited Servicing Righta 20 | B 24 ‘ 4 2 uy 15 Confidentiality 3 a 16 Governing Law And Dispute Resolution B 4 17. Specific Perfoomance, lanotion, Ete. B f 18 Miseetlareous 2 f Schedule 1: Loan Schedule 6 4 Schedule 2: Form of Notice of Assignment 2 aThis Loan Purchase anc Limited Seraicing Cpreement 's made tis day of 2012. Berwerns () ASSET MANAGEMENT ConrORATION OF NIGERIA, a statutory corporation ‘tablished under the Asset Management Corporation of Nigeria Aut No, 4 of 2010, and whose head office is st No, 21, Danube Street, Maituma, Abuje. (hereinafter ‘fered tous the “Corporation” ofthe one part. AND @). ENTERPRISE BANK LIMITED, a private limited ibility company incorporated under the laws of the Federal Republic of Nigeria, with RC muinber 969657, Hieeused to carry on banking business in Nigeria, and an Eligible Fibanaial Jostitution, and whose registered office is at Ploc 143, Ahmadu Bello Way, Victoris fsland, Lagos Ste, Nigeria (hereinafter referred to a3 tbe *Bank) oF the other part. Weneas: A) The Corporation is empowered under the AMCON Actto coquire loans whieh qualify as Fligible Bank Assets from Eligible nefal Insitutions. 1B) The Bank is an Eligible Financial Instinution, and it has cortaia rights, ile and intrest in and 10 certain loans, together with the Collateral, which qualify us Eligible Bank Assets, ©) The Bank is desicous of selling to the Corporation, and the Corporation is desirous of purchasing from the Banks the sights, tile and interest of the Bank in the Loans on (coms and conditions stated herein, Now, THeRevoRg, in consideration of the premises and mutual agreements set forth herein, land for other good and valuable consideration, the recsipt and adequney of which is hereby ssknowledged, the Corporation and the Bank hereby agree es follows:1 DerINTTIONS AND INTERPRETA ON 1 Definitions In this Agreement (including its reeitals and Sebedules), aniess the context otherwise requires, the following capitalised terms shall. have the sespective ‘meanings set forth below. Agent means any consultant, contractor, agent, representative, offices, servant, Frivy, employee or atomey of the Comparition or such other porson ‘designated by the Corporation to act on its bebalf; Agreement means this Loan Purchase and Limited Servicitig Agreements AMICON Act means Asset Management Corporation of Nigeria Act Ne. 4 of 2010; AMICON Guid ies mean the Guidelines for the Operation of the Asset Management Corporation of Nigeria, No. | of 2010, dated 15 November, 2010 and issued by the Central Bank of Nigeria; Bank shall have the meaning assigned thereto in the Pasties Clause; Borrower in relation to-a Loan, means a borrower or other obliges under any ‘Loan Document ar Collaveral Document in relation to such Loan end includes ‘without limitation a guarantors Business Day meens any day other than a Saturday, Sunday or public holiday, ‘on which banks in Nigeria are open for business; Collateral with respect to each Loan, means any tangible er intangible asset charged, pledged or mortgaged to secure such Loan, whether of the ower of such asset or a third party obligor or debtor, and she tern Collaterised and Collaterisation shall beconstrued accordinglys Collaterat Documents means the original (fo the entert available and, if not, certified true copy) of all dacuments, (ether than the Leen Documents), videneing or recording the Collateral or in connection with the Collaterisstion ‘9r evideneing the intestion of the dettor or other third party obligor to give Collaterel; Collection Account means eccount(s) maintsined by the Bank-or its agent for the deposit of principal and inverest payments and any other moneys received pursuant to the exercise of the Limited Servicing Rights in respect of the Loan Rights in connection with each Loan, or any moneys reeuived pursuact to the Reswicted Rights as required undor Clause {1.5“Consideration Bond” means a bond or other debt instrument tsted by the Corporation. and guaranteed by the Federal Govemment of Nigeria in scvorddancs with the provisions ofthe AMCON Aci; Effective Date means the date ofthis Agreement; Eligible Bank Asset has the meaning given ta the rerm in the AMCON Act and the AMCON Guidelines; Eligible Vinancial Institution has the meaning giver’ w the tenn in the AMCON Aot and the AMCON Guidelines; Events of Default means each and any of the events spscified in clauses 1211 wm 12.1.7; Tasurance Proceeds means proceeds of insurance policies insuring any Loan for any related Collateral; ‘Limited Serviciug Rights means the right to collect from th: Borower or any obligee moneys of any nature due under any Loan including peincipal, interest fees, taxes, Insutance premiums or other ineome, and to remit such collected moneys to the Corporation; Loan means each loan, overdraft, evedit facility er other fin accommodation deseribed, specified and Inehided in the Lonn Scheduler Loan Agresiment means the written agreement setting ou the principal tenins of each Loan executed by the borrower or obliges; Loan Docaments means the orginal (to the, extent aw lable and, if not certified tere copy) of all documents, agreements, ar instruments in relation to the Loan maintained or kept by the Bank or fs agont, (other chan the Collatera! Decurasats), in connection with the origination, acceptance nnd disbursement ‘of each Loan and includes all data, information, (both physivat snd electronic), credit facility documentation, books and records relating thereto including without limitation, the Lean Agreement; Loan Rights means the Loans on a servising release basis, that fe, with all servieing agreements or obligations relating to the Loa! (other than the Limited Servicing Rights), together ‘with all rights, title, interest, benefits, Feceivables and proceeds arising ftom and in connection therewith including without limitation the proceeds of, cash in or under, right fo, oF chose f action in relation 49, such Loan and all rights, ttl, interests, benefits and proceeds arising fom and in all Collateral and Collateral Documents connectedla es 138 iss Successors and Assigns ‘This Agreement shall bind ard inure to the benefit of and be enforceable by the Bank aod the Corporation and their respective successors und assigns. The Corporation may assign this Agreement ig whole or in part. This Agreement shall Bot be assigned by the Bank to a third party without the consent Gf the Corporation Amendients No term of provision of this Agreement may be waived oc subdified untess such waiver or modification is in switing and: signed by the party against ‘witom such waiver or modification is sought to be enforced Sarvival of Representations and Warranties ‘he Bank aurees that the representations, warraniles und agreements made by the Bank herein and in any cectificate or other instrument delivered! purguant hereto shall be deemed to be relled upon by the Corporation, notwithstanding any Investigation heretofore or hereafter made by the Corporation ot on the ‘Corporation's behalf, end thet the representations, warranties and agreements ‘nade by tho Bani herein or in any such certfieate or other instrument shall survive the Uefivery and payment for the Loans. Varther Agreements ‘The Bank ene the Corporation each agree to execute und deliver co the other Such reasonable and appropriawe additional documents, instruraeats or agreoments as may be necessary or appropriate fo effectuate the purposes of this Agreement. No Waiver ‘No waiver or acquiescence of any breach, or any continuing or subsequent lureach of any provision of this Agresment shall be construed as a waiver of any right under or arising out of this Agreement or aequiescnes to any ‘ocognition of any right and/or any position other than a3 expressly stipulated in this Agreement. Eatire Agreement This Agreoment sets out the entire understanding of the Parties in respect of the subject matter hereot, shall govern the yalldty, interpretation, performance and enforeement of this Agréement and supersedes all oral and weitten 4SCHEDULE2: Faux OF Nomce OF ASsiGNMeier OF Tees Loan iGnTs ‘Notice of Absighmént of Loan &-Loan Rights To: [pame:oF Boecosred) a fie ort Se 2 [Dar] Dest Sie, Nonice Op Assicxeat ‘Wo herby give you adtice tha by = Loan Purdie 8 Limited Service Ageeineat dae inert date}, (the Loan Purchase Agreement) betwesin [insertname uf Bank{ (she! Bank), and tye -ASSEr Moa.cepemt ConronaTION OY NIGERIA {he Ooepoction) (he Bai he sega 1 Ge Corpotition, absolutly all ts eighs, ile, interes, bean, ceceivaes and proceeds ‘ug Gem and in cosnecton with dhe [nn dcp of Lodnsnd Leon Again wb Bare, (the Contact therewith nehlng without Kiniaton the procee of, cath ia or uades th wo, ‘thot in action in elton te, such Tow nda igh, de, lamcet, beg nd peed slog im and eee tatemate peng to tha Cone, fle Calter sea “ah le ittces, Benelt, sectvables and procebde alsiog: Rom ani in counection with fos desciption of any secuity insuument executed wit the Boroue|, the Callatceal Ducumenp, conoected therewith but excluding for de woidanee OF doubi any obligation oe Jabiliy of the Bank under the Loan Agretnént ote Cle Dowuent Nobwidhstusing suc assignment, the Bank willzemaln table t perfocm all es obligations under tie Contact and the Compacetion shall have ao lsbility whatsoeyce in cespeettheseat: ‘Tas notice stall be goreened by and ednsiued in uccondange lth Nigedan laa ay dpe tuaderorin relation tot sell be mbject to ihe exclusive justtiction of the law courts af Nige “Yours ienlly, for snd on bell of Usterrraaie or Bana) 3918.10 understanding, negotiations or commitments of the Parties on the subject matter hereof, prior to the date frst above weltten, ‘Survival of Obligations “The tersuinution of this Agreement for any reason shall not release cither Party hhoceto fiom any obligation, which at the date of such termination has already ‘acerued to the other Party or which under the terms hereof or by its nature is & continuing obligation. 25Te | SB0essTeT 7 Tanvasaat [re assocass35 tao ones 8 | Decora has Givectooeaes— jas | aoa ae | 3vOOTSEBS 7 | aasoaraoss i Garvaorooesve a rODTOaTST Ta007S4EZ [oorreaiooeaze sone [ Taaeeis4 laa] isons asa2 [is [asonaisras a 290ccs0e 35 | aONTSRTAE Too | 1900074338 ‘37 unoccasiss ‘DEMAVS HOWINGS LTO 327,173,687.70 ohtverIN Wives Wetton, te Parties Herel have cased shoe eaed ther respective Cohmioh Seals to be hereuhte affixed on the day and your fist above written, ‘THe Common Sear O# ‘TU ASSET MANAGEMENT CORPORATION Of NIGERIA as bereunta affixed inthe presenes of ManacisoDieecron Dimzcror ‘Tne. Common SAL OF ENTERPRISE BAMICL TO. ws hereunto affixed is the prest Dinecton { pmscrovsnenraneANT | AKIN TAIWO.AND COMPANY CONSORTIUM Re: s7s616 HEAD OFFICE: 1, Rha Lane, Ogun Steet, Osborne Farah ABWA OFFICE: 18, Usuma Stoet Malan, Abga ee E85! HO Lao TEL: 01-6320147, 0808 326 5657, 0818 55 Een OU 68 2 50 £980, 0909 661 8759 10” june,2020 MR MOSHOOD ADEMOLA OMIDIRANI DEMAYO HOLDINGS LTD \ C/O MAGODO ESTATE \ q ‘ tacos Dear Sir, DEMAND NOTICE DEMAND FOR IMMEDIATE PAYMENT OF THE SUM OF Ni27,173,687.70 (ONE HUNDRED AND TWENTY SEVEN MILLION, ONE HUNDRED AND SEVENTY THREE THOUSAND ,SIX HUNDERED AND EIGHTY SEVEN NAIRA,SEVENTY KOBO .)BEING THE SUM UNPAID IN RESPECT OF A CREDIT FACILITY OBTAINED FROM ENTERPRISE BANK (NOW TAKEN OVER BY AMCON) We are Asset Management Partners (AMP) a CONSORTIUM appointed by Asset Management Company (AMCON) to recover debts due and unpaid, by DEMAYO HOLDINGS LTD. We have been asked to recover “by all means possible” outstanding sums due to AMCON with respect to a facility for N127,173,687.70 ( as at 2019 ) you obtained from ENTERPRISE BANK that remains unpaid. Please find attached, our letter of appointment. Please note further, that If after the expiration of the said seven days deadline, you have failed to liquidate your outstanding indebtedness to AMCON, we shall be left with no other alternative than to invoke the powers conferred on us by virtue of the sacrosanct Provisions of the AMCON ACT and other relevant statutes to deploy every available resource, as well as remedies to recover the said sum. We thankyou nantcpstion of yourcooperation and prompt response.) op Youts gincerety. poe? Dauds ise sigs iN PAIWO EOR AKIN TAIWO AND CO.CONSORTIUM ‘Alina A Taio BSc. FOR ACIT ‘Adeteke Onabanioen ENN? INIMENIA LID 11 Ajala Street, Osogbo, Osun State, Tel: 08033050606 7™ AUGUST, 2020 Et Ee MR. AKIN TAIWO AKIN TAIWO AND COMPANY CONSORTIUM, 1 RHIEF LANE, OGUN STREET OSBORNE FORESHORE ESTATE IKOYI- LAGOS Dear Sir, EMAND PAYMI FOR THE SUM. |127,173,687.70 ENTERPRISE BA! I write in respect of your letter dated 10" June 2020, in reference to the above subject matters. | wish to offer the sum of Thirty Million Naira as full and final payment for the debt noting that the actual credit facility was Ten Million Naira. The Payment of the said amount will be spread within the next Nine months despite the untold hardship of Covid-19 Pandemic that is ravaging all facets of our life. Despite my disadvantage position, | implore your good office to appeal to AMICON for a favourable response to my offer. Thanking you for your co-operation. We remain, Yobrs Sincerely, M. ADEMOLA OMIDIRAN For: Demayo Holdings Ltd~ Forwarded message —- From: MacMilton LP <1macmilton@gmail. com> Date: Sat, May 14, 2022 at 4:42 AM Subject: RE:DEMAYO HOLDING NIGERIA LTD; INDEBTEDNESS TO “ASE MANAGEMENT CORPORATION OF NIGERIA LTD’ ( “AMCON” )-FINAL DEMAND LETTER To: Ce: MacMilton LP All Directors Demayo Holdings Nigeria Ltd 11, Ajala Street, Osogbo, Osun. Tel:(+234) 706-811-2138 /omidiranfoundation: il Attention: (1) Moshood Ademola Omidiran (2) Wulayat Motunrayo Omidiran (Hon.Ayo Omidiran) (3) Abdulmalik Adedayo Omidiran Dear Sirs/Madam, RE: Hi LTD;: STEDI iS a NAC IN it IA LTD’ (“i ")-FIN, DEMAND LETTER The attached is for your kind attention. Treat as as urgent. Thank you. Yours faithfully For: MacMilton LP(AkKin Taiwo & Co Consortium) Mfom Ekpo, Esq.Off Corporation Dolphin Estate Ik Tah o704 1637712 E tmscuittondiemaiteom February 8, 2022 All Directors Demayo Holdings Nigeria Ltd 11, Ajala Sues sogbe, Osun, Tel:(+2: - Ayo Omidiran Foundation 1, Abubakar Baralola Park, Ibadan-Ife Expressway Ikire Osun State Street, Osogbo, Osun. Tel: 06-811-2138 E:[email protected] Attention: (1) Moshood Ademola Omidiran (2) Wulayat Motunrayo Omidiran (Hon.Ayo Omidiran) (3) Abdulmalik Adedayo Omidiran Dear Sirs/Madam, RE:DEM, DING NIGERL D;INDEBTEDNE: 'O_ ‘ASSET MANAGEMENT CORPORATION OF NIGERIA LTD’ ("AMCON”)-FINAL DEMAND LETTER We act for Asset Management Corporation of NigeriaCour Client”) on whose instruction and authority we writ to you.Reference is made to your Letter dated 7 August 2020 wherein you made a Proposal for the settlement of above debt. We note that your inaction on said Proposal indicates unwillingness and/or inability to give effect to the terms therein It is our Client instruction that other legal options be explored in ensuring recovery of this debt. As our extent law permits, this letter can sent to you by any electronic or social media means, namely: email, short media message, whatsApp, facebook, twitter etc, We note accordingly. Thank you. ‘Yours faithfully For: MacMilton LP(Akin Taiwo & Co Consortium) fr Mfom Ekpo, Esq.CORPORATE AFFAIRS COMMISSION, 022202600100 a Ss o 3 np e an PAYER WroRMariow awe Om eeronore cre 2 deuro HD ua, ‘meezeeegcinn com (etmtemmonn sass st Pavuenr oetas See eR me (SHLLER REQUIRED mroRUATiOn Pare oxen sumer Oa Peet MesseDEMAYO HOLDING (NIGERIA) LIMITED Registration Number iss Fe fr this compory | Officers 7 officers OMIDIRAN MOSHOOD ADEMOLA service adress NV AIALA STREET, O$0690, OSUN STATE eta © Rote -pikecton © Date of beth - Nik © Appointed on ni © Date of Removal - Nik © statue Active © emails, © Nationality - NIGERIAN © Place of residence - NIGERIA © Occupation - nit [ Fettow tis company OMIDIRAN WULAYAT MOTUNRAYO service scdess "NAIA STREET, OS0G80, OSUN STATE, Derails ® Rote oiRECIOR © Date of birth - nut © Appointed on - Nit © Date of Removal - Nit © status -ACTWE © email- Nit Nationality - NIGERIAN ace of residence - NIGERIA © Occupation - NIL OMIDIRIN ABDULMALIK ADEDAYO service aaress 11, AJALA STREET, 05080, OSUN stare, eral. © Role oiRectoR © Date of birth - Mi, © Appointed on - it © Date of Removal -NiL Ate9I0© status Active © emall nit © Natlonallty-NiceRIan | Place of residence - NIGERIA ® Occupation - Nik OMIDIRIN NURUDEEN ADESOLA seven adress SVAIALA STREET, ©5090, OSUN STATE Deca note pmkecron © Date of birth Nik * Appolnted on Ni. © Date of Removal - Ni. © status - active © email. © Natlonalty - NIGERIAN © Place of residence - NIGERIA 1 Occupation Nit, UNDEFINED UNDEFINED correspondance adds Ni Details ® Role nit © Date of birth nL © Appointed on - Ni. © status Inactive © email © Nationality - Nit © Place of residence - nil © occupation Ki ep co nee RRRSSOAS Mtb ecOHE ies. I28 gat 39a ee Page 1 of 3 AMCONE::... ASSET MANAGEMENT CORPORATION OF NIGERIA(AMCON) Serene ck Senerated On (Bate & Time): 09/03/2022 10:51:29 aM NAME OF cLieNT DEMAYO HOLDINGS LTD, ADDRESS ANCON ACCOUNT STATEMENT FROM 30-JUN-12 TO 08-FeB-22 LOAN ACCOUNT NUMBER : ae490000045526 PRODUCT NON NEGOTIATED Lo AMOUNT FINANCED are CURRENCY HaIGREEA een 2a CHEM [easier eran od rae rahe 2 Paid ToDate FREQUENCY ontniy ——-———- FUTUREVNSTALLMENTS | eae ayst | INSTL. PERIOD #12UCI2 70 3051632) unaovustep Amount [Pakemeeetl DISBURSAL DATE Bosun2012 OVERDUE CHARGES Sy o.oo) Sees one oa [arises i eemea TOTAL OVERDUE [sea zis) | im ACQUIRED EBA “a3773,0676, ee al some [Tiss ij eaaeng oe NET RECEIVASLE 5125820465) L SLOSING BALANCE __[——~S2eazzeg8 TRANS bare [Wate ome] PARTICULARS errs | eRebrrs | [[seun30i3—}-sosunsons [pening Bilence ~~ x00] [esa [sooo oustrcng cam Tar im iiaair 7a sag [3130-2019 13190-2083 Tove For eee 1.078 788:7) 0 2AuG-2012 | 31-uG-20%2 [bus Fees 4,620,157) og sabe 315602012 | 30-stP-2015 Joos For es > S| ser 78 oman 8 [Cavocr-20:2 | socraoiy fautreciee [382045798 15,063 6880 | SeNov-20127 "30-Nov-2012 [Due For interest $ ¥ 11567,894.76) 144,629,582, 9210r| [Tarpccani [Sree] [due For interest 6 —| 10 15795] “od iaraes [Stina | Srama0i3 ous rere 3 3,620,157) —— [asres 201s eaepanns [Ove For Interest 8 es ae) SEMAR 2013 | Si-hAR2055 oe Forinterst 628,157 5.0 SEAR 2015 90-0°R2013 [Bue For eres 0 —~ 567,594,781 — 152,524,319.9810¢| Sivav 2013" [3i-may2013 lowe Porites 11820.15734 ipiiai.a77. 5264] 30202013 | 30-10N2013 owe Farineesrts 4 155709373 7} SAO | 31 IU 2013 ove rorintaest 19 Sy—F 1,620,157.54) al 157250 or| 3¥ AUG 2013 ["3i-AUG-2013 Jove Forinarsa tp [isa 750,539,608 Sabr] 305562013 | 30-56-2013 [Bue For itso so 5705470 [i60.17563 38] 31-06F 2013, | St-ocT-2013 lous forinteee ir 2189) oles) http://172.20.10.42:7007/javalms/ReportDynaParam los 2/8/2022Account Statement Page 2 of 3 oN lowe For interest 17 | "31-0862013 [Ove For inerest 18 SEJAN-2014 [Due For Interest 19 9.00) _163,705,636.08)or 9.00) 365,325 794.02lor| 0.00) 266,945,951,56)or 25-2016 [Bue For ierest 30 100] 168,409.30 Due or Inara 3 9.90) 170,029,478 3] [_SB-APR-2014 [Ove For interest 22 67,3 7e|___ ot! “i74s87a73 doe | [31-May-2044 [ove For Inbred 23 4,620 15729!" ao0) “173.217 Saar SUNCRO:G |~300R-20%4 [Ove For nines 2 1557.91 76] 0.00] “srr ber] {atoucabi4 | sauc0ie [Bue Porters 1,620,153 576405 583 80)0r) BEAUG-20L4_ | “31AUG-2014 [Due Foriiteest 11620,157 Sa 785 741 20567-2014 [30-Sep-2014 Tove for tnerest 27 1,367 5 7 179553 695 abr [aeocr-20id | 3t0cr-2014 Tue Fr tnerea 35 1620 157 181,213,704 46 (Catov 2014" SeAi6v-20t4 Tue Fortes 1,367, «.7e| ool is,7ot 66.24 r| -Dk6 2014 | 3i-DC2024" [Due For Titec 30 620 (00) “4 40,8470 3-JAN-2015~ [Ove For interest 31 1.620157 50.00] 196,002,605 |” 26-Fe8-2015 [ove For terest 32 1463.:ch6, 000} e785 373.5 | SIeWaR 2015 [ove fortes 33 ool 188-08 31.80 ["socAba-2015 "| "30-AMR201S ove Fortine “so ~1905673496300 3a¥-2035 | 3:-HAY-2015 Jue For interest 3 100) 190,253 01.24 (~36s3un-2025 _|”30-1UN2035 [Due For Interest 36 S1JUL-2015 | 31JUL-2088” [Ove For nerest 37 6.00] —193,863,479.02 0.09 (aaus 2015 "| “31-AUG-2015” [Bue For interest 38 0.00 30-SEP-2015 [Bue For Interest 33 1563 0.00) 198,669, 699.68(0r 3LOCT-2018 [Bue For Interest 40 ‘SO-NOV-2015 [Sue For interest 44 “12EC-2015 [Due For Interest 42 201,477,800. “31-38N-2016 [Doe For Interest 43 208,088 058.2 a : 25-FES2016 [Doe For erst 4 AC 151515. 52. ou) 206,613,665 Zz x <= j 30, 29997 alr 201,887 742<0or [Steuar-2016 "| 31-maR-2016 [Due For Interest 45 4,620,151 341 0.00) 208,253,047, sor S:APR-2016 |”30-NPR2016 [Oye For Interest 46 SL-MAY-2016" | a-HAW-20%6 [Ove Fr tntresta> 302016 | 30-0006 [Oue Fa eres 312016 [Oue For inierest 5 S1AUG2016 [ous For Interest 30 SHSEP2016 [bo For Inara ST Si-OCT-2016 [Bus Forties 52 S00W2016 [ous Fer nest 53 [(3t-e 2016 Tove Fr intrest br Dr i or 4,562,191,761 o.oo “209.001 742 alo 4,620,575: ooo) 911, 42i.900 Seo br pr be or 4.58707] 0.00212. 569,795.3 1,620 15794] 00] 08383 1,620.15) 35] a0] aie, ,867.8)7:| —“to| 9 Poe an ol 90) 219,416,163 94 © o)200,986, 0587201 57.94 7225505, 216.66or 3IAN-2017 [Su For Imerest 55 620,15 04 224.206574.600r| (ase 2017 |26-Fep-2017” [ove For interest 56 1469.36.49 725,690,743 08 SiHAR2007_|"31-MAR-2017 [we For Interest 57 11620,357.34 227,308 91.0004| 30-APR-2017 | 30-APR-20L7 [Ove For Interest 56 1,567,095 70 228,577,795.780r ~3-AY-2017 [SI MAY2017 [Due For nero 59 3030N-3017_| 30 00N-Z017 ue For Interest 60 > [7 3tu.-20:7” | 31-2U1-2087” [due For Interest é “620,574 B-AUGI017_|91-nU6-2017" [Due For Interest 62 14620,157.94 735,306,164 3001 3082017} 30-52-2017 [Due For eres ad 236,874055.160r {3t0¢t-2017 [731-0cT-2017” [Due For interest 64 eX) 338,494,217 1010r) SONOV-2017 | SONOV.2017 [Ove For Interest 5793.79 340,060,11.881 ([Tacbec 205 sr-0e0%20%7 ove For intrest 66 e20.15/.3i 741,682,269.8215r | 3emi-2t:8 31-39-2018 ve For intrest 7 1,620.157.53] 0.0] 243 208487 76 8-6-2018 _|_26-Fe6 2018 Due For interest 6 1463.36. 344,765,796.22)0r SI-MAR-20i8 | 31-WaR-2016 [ove For tnerest 69 346,305 954 1 {H-APRGOIS | _30-APR2018 [Ove For Interest 70 1.00] 297 959,048 aor] [sna anie [SWAY 2016 [owe Focinarst 7: (60) 549 574,006 28 hitp://172.20.10.42:7007/javalms/ReportDynaParam.los 2/8/2022y © Account Statement j Page 3 of 3 ie | s0.22018 [ove For inert 72 SESULROTE | S1JU2016 bus or ines 73 SLAuG 2018 | S1AUe 048 [ous Fr seat ~so-sep-z018 | a0se2018- [ove For Inte 75 Siocr-2016” | S1-0cr-au8 [Dus Farinas 76 | Sonowanie[-aonov-aois fous Fortney SiDeC2016 | SL-peC aos" [ous Forres 7 siaawzoi9 | staiaoi0~ [bus Forres 7 2652019. _| 2p-e9-209[bue For nates SENAK 2010" S1-MAR-ZOLO [Due For tuaret st SOAPR-2019 | 30-APR20:9~[bve Fr irest Si-AAY-2019_| ST-MAV2019 [bus Far esas o> SOUN-2019 | 303093019~ [ove For rest [7 Stu a0i9 [313012019 "pve ror tnatec os 3186-2019" | 31-AN6-2018 [Due Fo lars 88 251101001 6¢or (25276205 cbr] 25439021 7p 255,950,112. 3210r] 35757027022] Ses san "30,758,307 Sor 262,379400 9) 263,841,903 365 82,007 3107] 57023, 502.1 br 0.0] 269,650,068 or ho] 270.217 951 Sab 00] 274839, 7epr 1505798 ogo} 273asp70.70or 30-SEP-2019 ove Fer interest 67 743478) 0.00) 275,26 65.<0r 3E-0C7 2010" [due Forineres Ta 5, 379, oo ” 26605 aor SO-NOV-2019, [due For terest 69 Ber 4,318 2b SL-DEC-2019 [Due For Interest 90 =x sz 834,376. 1dr! [Sigan-2020 “31-44-2620 |Oue For interest 91 ~~ Ti sun s7 Or 25-Feb-3620_|29-Fe- 2020— [Ove For Interest 92 SiS sue sat mares o07 ‘BI-MAR-2020 | “31-MAR-2020_|Due For Interest 93 > [1 675,157.94 0.00] 264,500,323.64)0r) i '30-APR-2020 [Due For Interest 94 1 55/534.78| 0.00)” 206, 58,216.421br] [SE RAY-20007 [Due For intrest 95 0, 52-9) 07573978376 360r] [30-Jun-3020 |” 30-3UN-2020” [Due For Interest $6 094,78) '319UL:2020 | 31-JUL-2020 [Due For Inerest 97 3%-AUG-2020_| “31-AUG-2020_ [Due For Interest 98 é 8.00) 269,346,271.14)0r 250,965,429.08)0r 37 252596,567.2r 30-SEP-2020 | 30-SEP-2020 [Due Fo intrest 99 31-01-2020 | 31-OCT-2020” [Due For Interest 100 é {[30N0v-2020 | -30-nov-an20"[oue For interest 101 = [Ctbecaoo— sree 2020 [bow ror tterest 102 SE Jagr 299,962 592.4 [stv-a0ar|"Ss-aan-202t” [Due For Interest 103 20 1579 300,582 95040, Or 2E-FEB-2021 | 28-FE8-2021 [Due For Interest 104 ‘SU-HAR-2021 |" 31-MAR-2021_ [Due For Interest 105 [ | so-aPe-202i |” 30-APR-2021 [Due For Interest 106 Si-MAY-202i_| 3i-MAY-3031 [Due For Interest 107 302,046,218.86)0r) | 303,666,376. 0)| 308,234,271 58)0r [ a Saar sar) 3osun-z0ai | 30308-2021 [ove For Interest 108 100) 908432.37430r| SEU-aizi [3801-2001 ve Fr intrest 109 oo) 10,002402 24] 3: aU: 300 [owe Fr inlerest 310 2:57] ool “sin e636s08r| ‘30-SEP-2021 [Ove For Interest 111 —.ss7.83476l 0.001 ~313,230534.9¢or Sacra ow or meee aurea sivenerradee S0-NOV-2024 [Bue For Inet £13 1 sot aia] 9.0) ganar er SLDEC 2001 [bve For interest tia 313AN-2022 |” 31-gAN 2002 |Oue For intrest 15 | saan-20227 [0e-Fe6-2002”[cesingBaiance ‘ora oo) 31038, For enquires contact Customer Services via [email protected]; ‘orxwEND OF REPORT® http:/172.20,10.42:7007avalms/ReportDynaParam.los, 2187/202210 | INTHE FEDERAL HIGH COURT NIGERIA j INTHE LAGOS JUDICIAL DIVISION i HOLDEN AT LAGOS SUIT 1.0. FHC/LLAMC/22/2022 BETWEEN: ASSET MANAGEMENT CORPORATION - CLAIMANT OF NIGERIA | AND 1 DEMAYO HOLDINGS (NIGERIA) LIMITED 2 MOSHOOD ADEMOLA OMIDIRAN 3 WULAYAT MOTUNRAYO OMIDIRAN DEFENDANTS 4 ABDULMALIK ADEDAYO OMIDIRAN VF E PUR | CERTIFICATE OF AUTHE\TICATION | 1, Eke Vincent, a litigation officer in Claimant’s Solicitors Law Firm in this Suit | hereby confirm the authenticity of the electronic mail and attachments therein of June 30, 2022 and its exchange with Chris Ee of Counsel to the Claimant about the following documents pleaded and/or referred in this Application: 1 Print out email dated June 30, 2022 EX 1 Print out Loan Repayment Agreement dated 2022 EX 2 Print out Demand Letter dated June 10, 2020 Ex 3, 4, 2020 EX 4, Print out demand Letter dated February 8, 2022 EX 5. Print out Corporate Affairs Commission Particulars of the Defendants EX 6. Print out 1* Defendant's Statement of Account dated February 02, 2022, EX7. 2 3 4 Print out Defendant's Letter dated 7° Aug, 5 6 7 SCHEDULE Computer Information 32 Bit Operating System-Microsoft Window 7 2009 Microsoft Corporation. Pentium® Dua- Core 74300u Printer Information HP LASER JET P1145zM Lalso certify as follows: That the document containing the statement was produced by the senbuter during a period over which the Computer was used ne ularly to Store or process of activities regularly carrie: on over trat perio ». That over that period there was Tegularly supplied to the Computer in the ordinary course of those activities information of the kind contained in the statement or of the kind from which information so contained is derived, ¢. That through the material Part of that period the computer was operating properly; 4d. That the information contained in the stateinent reproduced wi is derived from information supplied to the Compute: in the Ordinary course of its activities, T attest to the information produced as being true and accurat: Dated this Gh , 2022 Name: Eke Vincent " Desgination: Senior titigation Officer soronme BHO) C" Bre Esq MACMILTON LP (Akin Taiwo & Co Consortium) CLAIMANT'S COUNSEL No 70A Itafaji Road Dolphin Estate 1koyi Lagos Emall: ame som, lel: 08063271821,08033265657 FOR SERVICE ON THE DEFENDANTS 11, Ajala Street, Osogbo, Osun. Tel:08033050606 E:[email protected]