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  1. IN THE HIGH COURT OF JUSTICE CLAIMNO: HQ14D02898 QUEENS BENCH DIVISION B E T W E E N: FRANK KOFI OTUO Claimant & JONATHAN DAVID MORLEY 1st Defendant & WATCHTOWER BIBLE AND TRACT SOCIETY OF BRITAIN 2nd Defendant RE-AMENDED PARTICULARS OF CLAIM The Claim 1. This is a claim in slander against the First and Second Defendant. The Slander 2. The First Defendant is an “Elder” appointed by the Second Defendant to oversee its affairs in the Wimbledon Congregation of Jehovah’s Witnesses. The latter is now being held vicariously liable for the malicious slander of the Claimant at a meeting set up by the First Defendant on the 22nd of June 2013 about 8:00pm, to mend a strained relationship with the Second Defendant. 3. The objective of the meeting was to seek reconciliation and reinstatement to the Second Defendant’s Organisation after a contentious disfellowshipping action taken against the Claimant that was premised on a false and malicious allegation of fraud against the Claimant. The Claimant does not accept that he is disfellowshipped. BACKGROUND 4. The First Defendant summoned the Claimant to a brief meeting on Sunday the 30th December 2011. He informed the Claimant that, a fellow congregant, Mr Robert Wee had written a letter to the Body of Elders of the Wimbledon Congregation of Jehovah’s Witnesses accusing the Claimant of fraud. The Claimant requested for a copy of the letter of accusation but the First Defendant refused to produce it and has not, to this day. The Claimant was informed that a “Judicial Committee” had been set up to hear the facts of the case and rule on it on Friday 6th January 2012. The Claimant’s attendance was thus mandated. 5. At the close of the said meeting, the First Defendant informed the Claimant that the accusation was founded and as such a decision has been made to dis-fellowship the Claimant from the Congregation and as such the worldwide organization of Jehovah Witnesses. 6. An announcement was made to that effect on the 19th July 2012. By this announcement, the Claimant avers that he was defamed by the 2nd Defendant. This is now subject to a separate claim in this Court pending judgement on the Claimant’s application to dis-apply s4A of the Limitation Act 1980. 7. At the meeting for reinstatement, the First Defendant made the accusation of fraud and the exact terms of the accusation are particularised as below; The words complained of are: “So just going back to July of last year when you were disfellowshipped, I think it was July 19 that it was announced to the Congregation, is that correct? I think it was do you … how do view then, what you were disfellowshipped for? Do you understand what you were disfellowshipped for?... just to summarise what I thought you have said, is that even today, you would not accept it was fraud … That is what you seem to be saying? … Is that your position?” … no that’s fine… we respect that and appreciate, we would not want you to lie to us, that will be counterproductive anyway because...ok, we appreciate … I guess the only question I will like to ask you, Frank though is, you got four brothers here who spent a lot of time on this matter as you know, you had three other brothers on the appeal committee, who spent a lot of time on it and after that, the Branch had a look at all of it, so, do [sic], have you not considered that, with that process that was gone through and that the conclusion was, on the part of the of the original committee, the appeal committee and the Branch that it was the a fraudulent situation, do you not feel that you ought to really reflect on whether you’ve understood the matter correctly?” 8. The publication of the words complained of was made in the presence of Mark Lewis, Collin Smith and Andrew Sutton. 9. The natural and ordinary meaning of the words complained of is that; the Claimant has been disfellowshipped from his congregation for committing the act of fraud. 10.The innuendo meaning of the words complained of to those present is that; the Claimant has been disfellowshipped from his Congregation of Jehovah’s Witnesses for unrepentantly committing the act of fraud. The special fact relied upon by the hearers to derive the innuendo meaning is that they were aware of an earlier allegation of fraud brought against the Claimant by the Second Defendant on the premise that it had been alleged by a fellow congregant, Robert Wee. There was however no confirmation of the accusation by the alleged complainant back then and to date. Malice 11.The Claimant vigorously denies the allegation of fraud and has consistently maintained his innocence. The First and Second Defendants conspired to harm the Claimant, by, amongst many other facts to be explored at the trial, being indifferent to the truth or falsity of the defamatory allegations complained of, thereby precluding the Defendants from having an honest believe in their truth. Damages Suffered 12.The Claimant has suffered a near irreparable damage to his reputation, emotions, physical and psychological and has reduced my standing before the hearers of the words complained of and community-at-large. 13.The damage suffered by the Claimant following the repetition of the slander by the 1st Defendant is cumulative upon the original the slander of the disfellowshipping by the 2nd Defendant announced to the Congregation twelve months earlier. The Congregants are also mandated by the teaching of the Second Defendant to repeat the slander to all who are Jehovah’s Witnesses but not necessarily members of the Wimbledon Congregation. This implies that the extent of defamation is worldwide and last a life time. 14.As a direct result of the gratuitous slander by the First Defendant at the said meeting, the Claimant was a fraudster and thus unfit to be reinstated into the Church. This has led to continued ostracism by the Claimant’s family and friends reinforcing and aggravating the damage done to the claimant’s reputation. 15.In a further aggravation of the damage caused; the slander has been republished in the London Evening Standard which boasts readership of over two million. This has subjected the Claimant to further ridicule and humiliation in his neighbourhood and community–at-large. The Claimant holds the Defendants responsible for the damage caused by the republication. 16. The republication, it is averred, to be the natural and foreseeable outcome upon a suit, as the 2nd Defendant enjoys an unenviable press interest. The 2nd Defendant was thus fully aware, upon notice of proceedings in a pre-action protocol, that if she does nothing to retract an unfounded allegation of fraud and proceedings ensued, the inevitable outcome was a press article in a major newspaper and a repeat of the slander that will lead to further substantial damage and aggravation of damages to the Claimant’s reputation. 17.See
      Hello guest!
    [sup…]. 18.The Claimant has continued to suffer extreme shunning by friends and family occasioned by the Defendants actions. 19.My three young children, who are pubescent to teenage, are finding it extremely difficult to cope with the fact that their Dad has been ostracised by the only community they have ever known since birth. This is in addition to the spiritual harm and mental distress caused to me as a direct consequence of the action. 20.I have lost all my friends who were only Jehovah Witnesses as they are not allowed to speak to me lest they face the same fate. 21.I have not travelled outside the UK, especially to see my ailing mother or any of my family members who are also members of the Organisation and as such barred from receiving me. 22.I lost my fundamental rights [Article 8 of the Human Rights Act] to my family as consequence of the sustained action by the Defendant and shall not regain it unless I admit to fraud and say I have repented of it. This is something I am unable to do conscientiously. 23.I have lost a least seven hundred regular friends I have known for up to forty years now. I had the privilege of service and associating with at least fifteen thousand such ones annually at the annual District Convention of Jehovah’s Witnesses. 24.The worship and faith was in essence everything my family and I lived for. It was our lives and everything else revolved around it. I am not allowed to have any spiritual association with my own wife and children. Breaches of the Claimant’s ECHR 25.The Claimants submits that the actions of the Defendant breaches Article 8(1) of ECHR which states; “Everyone has the right to respect for his private and family life, his home and his correspondence.” The Defendant’s publication of the words complained of and sustaining it has led to the continued loss of family life and the right of correspondence with his family. 26.The Claimant further submits that the actions of the Defendant have breached the Claimants right under Article 9(1) of the ECHR which states; “Everyone has the right to freedom of thought, conscience and religion; this right includes freedom to change his religion or belief and freedom, either alone or in community with others and……” The Defendants’ actions have wrongfully usurped the Claimant’s right of expressing his religion and affiliation with his chosen religious community. What the Claimant seeks as Remedy The Slander 27.Seeks an injunction to barr the Defendants from repeating the alleged slander in any form communicable. 28.The Claimant seeks damages of £175,000.00 for reputational, emotional and psychological damages occasioned by the Defendants actions. 29.The Claimant seeks aggravated damages as consequence of the Defendants unreasonable behaviour subsequent to the accusation. DATED: 1st February 2016. I BELIEVE THE FACTS STATED IN THESE PARTICULARS OF CLAIM ARE TRUE. SIGNED………………………………………………………………………… FRANK OTUO.

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