Demand note

JUNGU ATTORNEYS,                       

P.O. Box 00000                              

Dar es salaam.

Attn: Mr. ccccccccccc,

Dear Sir,

Re:       Unlawful Termination of Employment of

Mrcccccccccc after attack on him on 7^th January 2000

We act for Mr. ,,,,,,, aforestated (hereinafter called "our client"), upon whose instructions we write to you as follows: -

Since 1988, our client was engaged by your Organization as a Consultant. The terms and conditions of our client's contract of employment were as contained in one -year Consultancy Agreements which by mutual consent of the parties, were renewed as and when the same expired. The last of such Agreement was signed by the parties on 8^th July, 1999.

In the early morning of 7^th January 2000, whilst our client was in the ordinary course of his employment, he was attacked by a clique of members of the I.C.R.C Somalia Delegation who are well known by our client, details whereof are well within your knowledge. We are instructed that this was a malicious internal scheme, which had been skilfully organised under the conspiracy of two of your employees, agents or servants namely, Messr. Abdiaziz Osman Mohamoud and Raymond Deserzens against our client, with the aim of frustrating his efforts to perform his duties efficiently and/or eliminating him altogether. As subsequent events revealed, the said heinous act was perpetrated with the active collusion and connivance of your organization and every effort was made thereafter to conceal the facts. It is unfortunate that your organization, as an international humanitarian organization, could have engaged in or condoned such illegal acts.

In addition to the foregoing, your organization purported to terminate our client's contract of employment without any lawful basis for doing so. Even then, your Organization refused, neglected and/or otherwise failed to pay to our client such sums of money and other compensation as was lawfully due to him.

Pursuant to the foregoing, we are instructed that pursuant to the express and/or implied terms of the said Consultancy Agreement as read together with the Consultancy Regulations, our client is entitled to claim the following from your organization: -

1             Compensation for wrongful termination of our client's contract of employment.

2              Salary for 12 months in the sum of US$ 21,960.

Despite numerous reminders to yourselves, you have refused, neglected and/or otherwise failed to respond to our client's letters and/or make good his bona fide claim.

Accordingly, our instructions are to demand from you, as we hereby do, that you confirm to us in writing, within the next SEVEN (7) DAYS that: -

a)             You shall immediately reinstate our client to his employment without any loss of status, emoluments or benefits attendant thereto.

b)            You admit  liability to pay to our client forthwith:-

i)              The compensation and amounts referred to in numbers 1-3 above.

ii)             General damages for such pain, loss and suffering as our client has been subjected to as a consequence of the said attack.

iii)            Such sum of money, representing future medical expenses, as are payable to ensure complete recovery by our client.

iv)            Any such further compensation as may, subsequent hereto, come to light.

TAKE NOTICE that unless we receive your positive response as aforestated with the stipulated deadline of SEVEN (7) DAYS of the date of this letter, our instructions are to institute legal proceedings against yourselves without any further recourse to yourselves whatsoever, holding you liable for all costs thereby incurred and other consequences ensuing therefrom.

We trust that this will not be necessary and we look forward to hearing from you within the aforementioned time.

Yours faithfully,

sssssssssssssss

cc.          1.         Client

            2.         sssssss.

DRAWN BY;

JUNGU ATTORNEYS

P.O.Box 00000

DAR ES SALAAM TANZANIA.