Scripture Union Centre, . 2nd Floor Rm 202, Argwings Kodhek Road, Hurlingham, P.O.

Box 29166 - 00100 Nairobi, Cell: +254737861 093, E-mail: info@chelangadvocates.com www.chelangadvocates.com

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CHELANGA
COMPANY ADVOCATES

National Cohesion and Integration KMA Centre, 6 Floor Mara Road-Upper Hill P.O Box 7055-00100 NAIROBI
th

Commission

We refer to the above matter and your letter dated 1th March 2012 notifying our client Dennis Itumbi of a complaint lodged with you by undisclosed complainant whom you conveniently referred to as "a concern Kenyan (sic)".

Whereas our client maintains innocence in respect of any allegation of hate speech on facebook or at all and shall shortly make an application to strike out the complaint for being frivolous, vexatious and lacking in substance, he has instructed us to demand from you, which we hereby do to furnish us with the follOWing further particulars of the complaint a) b) c) d) e) to enable him appreciate the full tenor of the complaint lodged: Itemized verbatim facebook posts subject of the complaint and your investigation; The nature of threats in such posts; The alleged communities, class or group of persons in Kenya which said posts intended to cause hatred and violence among; The identity of tl1e complainant; Any further particulars tl1at would allegations against him. Furnished with the requested lawful investigation information, our client is ready and willing to assist the commission in any

enable our client to comprehend

the nature

and extent

or the

of the matter.

Yours faithfully, CHELANGA & COMPANY