i {rites Ltr: 4. IN THE SUPERIOR COURT OF. Aiea RE’ 0 asap _IN THE HIGH COURT OF JUSTICE a fig GENERAL JURISDICTION ur ee ACCRA-AD.2021 eer ree eR Suit no: CHANTELLE T.S KUDJAWU — | oo VRS = GLORIA ASSAN ARHIN . DEFENDANT J STATEMENT OF CLAIM (Order 11, Rule 1 OF C147) Plaintiff is a citizen of Ghana and at all material times a wife, mother of three and a Private Investigator of 10 years Defendant is from her name, presumed to be Ghanaian and holds herself out as a homemaker in Ghana that is pursuing a divorce from her husband who is a public figure that works within government. As a wife, mother and successful businesswoman, Plaintiff is very highly respected by y both locally and abroad especially as Plaintiff has by virtue of her practice as a Private Investigator worked with various individuals, bodies, institutions and organs within and outside Ghana, uated with a Master’s Degree in Political Science from [ERR 010s Cortiicae rom titvard University = Plaintiff has worked as a Political Consultant, a Private Investigator, a Real Estate Developer and the CEO of several businesses. Plaintiff also volunteers regularly.7. Plaintiff contends that her position as head of an international organisation, as well as the office she holds in international circles all attest to and serves as demonstration to the high sense of integrity, dignity and respect Plaintiff commands and enjoys in her field of endeavor from her colleagues both in Ghana and internationally. 8. Plaintiff has by dint of hard work built a reputation for herself not only in her career as a Private Investigator but also in very many spheres of life having taught several persons who are private investigators today and who still hold Plaintiff in high regard. 9. PlaintifF states that her integrity and reputation as an astute and responsible mother of three, with a supportive husband, charity and bourgeoning private investigation practice enabled her to raise intemational awareness for her charity and obtain more assignments as a private investigator. 10, Plaintiff says that the Defendant's defamatory statement against the Plaintiff, in paragraph 14(a) of the Defendant's divorce petition filed in the High Court of Justice, on Wednesday February 10, 2021 was carried globally through the internet in the form of being published on online platforms from Thursday February 11, 2021 to date in a statement titled: “Particulars of adultery: a. The Respondent has other women in his life with whom he has extramarital affairs, including one Chantel Kudjawa (Gertrude Gbajo) whom the Respondent continues to have extramarital affairs with” 11, Plaintiff says that the publication pleaded in paragraph 10 above, was made of and concerning Plaintiff who is otherwise known as Chantel Kudjawu, 12, Plaintiff avers that the Defendant made this statement that was widely published, the subject matter of this present suit, with malicious intent. 13. Plaintiff denies that she has ever engaged in the activities alleged by the Defendant and states that she is a principled and law abiding professional who does not compromise on the integrity and dignity of her marriage 14, Plaintiff avers that the publication pleaded in paragraph 10 is a false statement purporting to be fact which was published and communicated to the general public and this fault amounted to at least negligence and damages as well as harm caused to the Plaintiff who is the subject of the statement. 15, Plaintiff further avers that the public is not aware of the circumstances surrounding a leaked video call involving one Mr. Albert Kan Dapaah, and the Defendant has taken advantage of this misrepresentation to damage the Plaintiff's reputation publicly and globally, 16, Plaintiff avers that she has also never had an amorous relationship with Mr. Kan Dapaah, Indeed, Plaintiff has met Mr. Kan Dapaah only once in her life, with all other interactions being held purely on phone. 17. Plaintiff says that the defamatory statement cited in paragraph 10 above has by the 15" February 2021 attracted thousands and thousands of comments, majority of which were pejorative and deprecatory of the Plaint 18, Plaintiff states that by reason of the publication of the said defamatory words particulars of which are contained in paragraph 10 (supra), the Plaintiff has been brought into public soandal, odium, contempt and ridicule,19, Plaintiff avers that in terms of the statement pleaded in paragraph 10 above, the Defendant ‘meant and is understood to mean that the Plaintiff is perverted in character, dishonourable, without credibility, of perverted behaviour and fell short of public morality by causing the Defendant’s husband to commit adultery with the Plaintiff and he is to date allegedly still having an affair with the Plaintiff. 20. Plaintiff avers that the Defendant's written statement was widely published and the words complained of were published without any facts justifying the allegation of extramarital affairs against Plaintiff and further, these allegations imputed to Plaintiff in the offending statement are baseless and false. 21. Plaintiff says the Defendant made this publication carelessly and recklessly, without lawful excuse or justification and was calculated to injure the Plaintiff's reputation and to expose her to ridicule and hatred. 22, Plaintiff says that the Defendant’s publication has lowered the Plaintiff's reputation in the eyes of well-meaning and right thinking people in society and as a result, she has suffered great distress, embarrassment and damage to her reputation both locally and internationally. 23. Plaintiff avers that after the offending statement was published on multiple online platforms including Ghanaweb, Yen, Facebook, Twitter and Instagram, she received several phone calls and messages from her family, friends and business associates who had read the offending statement, asking about the statement made against the Plaintiff and its contents since the statement had also been copied and circulated all over WhatsApp and other social media platforms. 24, Plaintidf avers that the said defamatory words were published and circulated with the sole intent of reducing her in the estimation of all right-thinking persons reading it in Ghana and all over the world. 25. Plaintidf avers that the Defendant is pursuing this course against the Plaintiff because the Defendant believes that damages to be paid in publishing the defamatory matter about the Plaintiff would be outweighed by the profit that Defendant stands to make in defaming the Plaintiff 26, Plaintiff avers that unless restrained by this Honourable Court, the Defendant will continue to publish such defamatory words complained of and more. 27. EREFORE the Plaintiff claims against the Defendant for the following reliefs: A declaration that the Defendant’s defamatory Statement against the Plaintiff, in paragraph 14(a) of the Defendant's divorce petition filed in the High Court of Justice, on Wednesday February 10, 2021 and carried globally through the internet in the form of being published on online platforms from ‘Thursday February 11, 2021 to date in a statement titled; “Particulars of adultery: a. The Respondent has other women in his life with whom he has extramarital affairs, including one Chantel Kudjawu (Gertrude Gbajo) whom the Respondent continues to have extramarital affairs with” Is false, wicked, malicious and defamatory of Plaintiff. ji, A declaration that the Plaintiff's reputation has been injured by reason of the false, malicious, unjustifiable and reckless defamatory statement uttered by the Defendant,An order of the Honourable Court directed at the Defendant to publish an unqualified retraction and an apology on Ghanaweb, Yen, Facebook, Twitter, Instagram and Daily Graphic print and online with the same prominence the defamatory words received within 14 days after the judgment iv. An order of the Honourable Court for perpetual injunction restrai Defendant from further publishing any defamatory material about the Plaint v. Damages in the sum of Three Million Five Hundred Thousand Ghana Cedis (GHE3,500,000.00) for the defamatory statement published in the Defendant's divorce petition filed on Wednesday February 10, 2021 and published globally online from Thursday February 11, 2021. vi, Aggravated damages for the reckless and malicious publication of the said statement vii, Exemplary damages for the reckless and malicious publication of the said statement Compensatory damages for the damage done to the Plaintiff's reputation viii, Cost DATED AT CLINTON CONSULTING PARTNERS, 9™! FLOOR AMANDA AKUOKOR CLINTON LAWYER FOR PLAINTIE LICENCE NO GARO CHAMBERS NO PPI THE REGISTRAR, HIGH COURT, GENERAL JURISDICTION, ACCRA. AND TO THE ABOVE-NAMED DEFENDANT OR HER LAWYER