i) Sometime in 1998 CHEVRON NIGERIA LIMITED desperately needed to acquire additional land in the Ugborodo Community and accordingly contacted the bona fide and legitimate organ of the Ugborodo Community entrusted with such responsibility, the Ugborodo Community Trust.

ii) The Ugborodo Community Trust is a statutory body, registered since 1985 under the Land (Perpetual Succession) Act, 1958. The Trust aforesaid, inter alia, is empowered to manage, protect, control, administer in conjunction with the Council of Elders, the Ugborodo Community land.

iii) On the 15th day of April, 1998 Chevron Nigeria Limited led by Mr. O.A. Omole, General Manager, Public Affairs and the Community Representatives herein aforementioned legally transferred the land to Chevron Nigeria Limited.

iv) Three months after the aforesaid transaction, but before the monies/consideration due upon same was paid, the community duly reconstituted the Ugborodo Community Trust and the late Mr. S.A.K. Metseagharun was elected chairman.

v) Late Mr. S.A.K. Metseagharun was a one time Chairman/Administrator of Delta State Board of Internal Revenue and the Secretary/Treasurer Ugborodo Community Trust Caretaker Committee, before his election as Chairman of the Trust aforementioned.

vi) Late Mr. S.A.K. Metseagharun was retired from government (albeit prematurely) in January 1997 at the age of 56; he was a Tax Consultant and ran his private business until his untimely and gruesome murder in broad daylight.

vii) The late Mr. S.A.K. Metseagharun was an astute man and incorruptible and it was this quality that made Chevron Nigeria Limited and the likes of O.A. Omole and Joe Jakpa to plot and encourage his elimination.

viii) Some senior officers of Chevron Nigeria Limited were arrested pursuant to the averments herein above and accordingly prosecuted for their surreptitious involvement in the disbursement of funds meant for the community.

Herewith annexed and marked ‘A’ is a copy of Charge No: A/113/2000 involving some Chevron Nigeria Limited senior staff.

ix) On the 16th of September, 1998 the late Mr. S.A.K. Metseagharun, notified the Managing Director of Chevron Nigeria Limited of the activities of some senior staff of the company, their greed and apparent disregard for constituted authority and the due process, but the Managing Director did nothing to stop these men and their clandestine operations. Herewith annexed and marked ‘B’ is a copy of the letter aforesaid.

x) Exactly one week after the letter aforementioned was delivered to Chevron, Mr. O.A. Omole visited the late Mr. S.A.K. Metseagharun in the company of 2 other staff of the company to solicit his co-operation in their clandestine plan to defraud the Ugborodo Community and he bluntly refused.

xi) The Management of Chevron Nigeria Limited knew about the existence of the Ugborodo Community Trust, their powers and functions and they have been warned severally by all well meaning citizens of Ugborodo Community, the Itsekiri nation and even the Nigerian Police Force, but they bluntly chose to do otherwise. Herewith annexed and marked ‘C’ is a copy of a letter dated 2/06/99 from the Commissioner of Police, General Investigation Section, Force CID, Alagbon Close, Ikoyi-Lagos.

xii) After Chevron Nigeria Limited through illegal monies paid to Mr. Sandys Omadeli Ovwoh and his gang (see Charge No: W/9C/98) had eliminated the astute and incorruptible Chairman of the Ugborodo Community Trust, they now went back to continue to deal with the same trust they had earlier on neglected. Chevron Nigeria Limited are in possession of correspondences establishing this fact, they should accordingly produce same.

xiii) In November 1998, Chevron Nigeria Limited pursuant to the averment herein above arranged and sent a plane to collect the Trust executives from Warri to Lagos for negotiations, and the plane crashed, five minutes to landing in Warri. Chevron sent their apology and fixed another meeting for 10/12/1998, which they never kept.

xiv) Chevron Nigeria Limited quite contrary to the above averment caused a notice for an Ugborodo General meeting to be published in the Punch Newspaper of 25/02/99 giving a 24 hours notice for the meeting in Ugborodo on 26/02/99.

xv) Mr. O.A. Omole, Chevron’s General Manager, Public Affairs arranged a plane for his gang. There were no representation from Benin, Sapele,Warri, Ogidigben, Ajudaibo, Madangho, Jaghala and even Ode Ugborodo because the people were not aware of the meeting.

xvi) At the Chevron Nigeria Limited arranged meeting aforementioned, Chevron set up an illegal interim committee to enhance their surreptitious operations in the community.

xvii) The Council of Elders were not aware and did not attend the illegal meeting aforesaid. The Registered Trustees, and the Governing Council of the Trust did not attend the illegal meeting.

xviii) All these Chevron Nigeria Limited did even after they had been properly advised that the Trust had won 3 High Court Judgements in row (Warri High Court in June 1998, Federal High Court, Benin 14/08/98 and Effurun High Court in March 1999) and that the Trust was the only body empowered to act for and on behalf of the Ugborodo people.

xix) The Council of Elders protested to Chevron Nigeria Limited on the aforementioned illegality. The Legal Advisor of the Trust in a strongly worded letter dated 23/03/99 also complained of the aforementioned illegality to the Management of Chevron Nigeria Limited.

xx) By a letter dated 2/04/99 the Trust Public Relations Officer specifically complained to the Managing Director that Mr. O.A. Omole demanded a 15 million kickback. There has been no response to this allegation and several others.

xxi) Chevron Nigeria Limited had always known the right persons to deal with, but instead intentionally funded, encouraged and collaborated with the group that killed the late Mr. S.A.K. Metseagharun because he would not agree to their plan to defraud the community.

xxii) By a letter dated April 26th, 2000 Chevron Nigeria Limited through O.A Omole requested the intervention of an elite Itsekiri group, known as and called Committee of Concerned Itsekiri Citizens. A copy of the Committee’s report and the letter of Mr. J.O.S. Ayomike dated 7/08/2000 and 2/05.2000 is herewith annexed and marked ‘D’ and ‘E’ respectively.

xxiii) The petitioners shall at the hearing before the Commission rely on all the documents referred to herein, particularly the Report of the Committee of Concerned Itsekiri Citizens and the letter of Mr. J.O.S. Ayomike.