THE REPUBLIC OF UGANDA THE CIVIL PROCEDURE AND LIMITATION (MISCELLANEOUS PROVISIONS) ACT NOTICE TO INTENDED DEFENDANT

IN THE MATTER OF AN INTENDED SUIT BETWEEN

JOEL ISABIRYEINTENDED PLAINTIFF VERSUS 1. THE NEW VISION PRINTING AND PUBLISHING CO. LTD 2. THE EDITOR IN CHIEF OF THE NEW VISION AND THE KAMPALA SUN NEWS PAPERS.INTENDED DEFENDANTS

NOTICE TO INTENDED DEFENDANT

1. TAKE NOTICE that JOEL ISABIRYE ( herein after called the intending plaintiff) of C/O M/S Kayondo, Omony & Co. Advocates, Plot 822 Rubaga Road, P.O BOX 1643 Kampala intends to institute a suit against the above named intended defendants in the High Court of Uganda by which he will seek general, special and exemplary damages for libel/ defamation. 2. The facts constituting the cause of action which arose on the 2nd of May 2014 are here below; a) That on the 2nd day of May 2014, the intending defendants caused to be published in the Kampala sun news paper on pages 1, 3 and 5 an article entitled Woman behind Isabirye, Jingo fight by which they falsely and maliciously alleged that the intending plaintiff is among other things a philanderer who had impregnated another woman not being his wife and as a result, that there is a fight between him and his wife Rebecca Jingo.

b) That the intending plaintiff will aver and adduce evidence in court that this article was maliciously written and caused to be published by the intended defendants with the sole intention of bringing the intending plaintiff into hatred, contempt and ridicule in the eyes of all right thinking men in Uganda and internationally. He shall further aver that he does not know the said woman and has never met her or impregnated her and has never been to Nagalama to her parents place or even on a working trip to Nairobi since his wedding as alleged in the article. That he has further not had four marriages in the last ten years as alleged and further that he has never snatched any woman from a mzungu and more so he has been accused of recycling women as men recycle socks in the article. c) That the contents of the said article by inference means that the intending plaintiff is; a violent, immoral and adulterous person and a person of questionable character. That the fact of putting his photograph and that of his wife and family on the first and other pages of the Kampala sun news paper was high handed, malicious and an infringement on his privacy for which he shall seek punitive/ exemplary damages. d) That the intending plaintiff is PHD holder and a renowned media consultant who has published world wide and who has handled contracts with the following reputable national and international organizations for which he may not to be considered again as a result of the perception of his character and integrity as portrayed in this article by the sun news paper for which he intends to seek and prove special damages for cancelled contracts/ loss of income/ loss of sales/ grants; i) The French Government ii) The American Government iii) Uganda Revenue Authority iv) FORD foundation, DANIDA, Belgian Technical Co-operation ( as a recipient of grants) v) Makerere University (visiting lecturer) vi) Harvard University (guest speaker) vii) Mississippi State University ( Assistant professor of communication since 2011) vii) Uganda Film and Television Institute (Lecturer) viii) Institute of communication studies in Uganda, ICS (Director)

ix) The Pepper publications, Vision group, Nation media group. x) EBALUWA newspaper (proprietor) xi) Super FM, Beat FM, Kingdom FM, Kiss FM, Capital Radio-Juba, Dembe FM xii) Broad Cast Educators Association, BEA (member) xiii) International Association of the study of popular music (member) xiv) International communications Association( member) xv) Monday Times on line ( proprietor), with advertisers and 600,000 views sofar. xvi) Author of expressing federo; popular music in Bugandas quest for federo in Uganda being sold on AMAZON and which sales stand to be affected by the article. d) That as a result of the intended defendants malicious, libelous, defamatory conduct, the intending plaintiffs seeks compensation/ damages of Ugs. 2,000,000,000/= (Two billion shillings) e) The value of the subject matter of the intended suit is well over 5,000,000,000/= ( five billion shillings)

DATED at Kampala thisday of .2014

COUNSEL FOR THE INTENDING PLAINTIFF

Drawn by; Kayondo, Omony, & Co. Advocates Plot 822 Rubaga Road, Opposite Red Cross Head offices, P.O Box 1643 KAMPALA