i 2; t 2, ACCRA ~ A.D 2018 WRIT NO.. WRIT INVOKING THE ORIGINAL JURISDICTION OF THE SUPREME COURT BETWEEN CITIZENGHANA MOVEMENT NO. 22 GUGGISBERG AVENUE DANSOMAN, ACCRA. PLAINTIFFS, IMANI CENTRE FOR POLICY AND EDUCATION UNNUMBERED HOUSE, KOANS ESTATES. POKUASE, ACCRA AND. THE MINISTER OF COMMUNICATIONS 5 MINISTRY OF COMMUNICATIONS MINISTRIES, ACCRA. DEFENDANTS THE ATTORNEY GENERAL & MINISTER OF JUSTICE MINISTRY OF JUSTICE MINISTRIES, ACCRA. TO: 1. THE MINISTER OF COMMUNICATIONS MINISTRY OF COMMUNICATIONS MINISTRIES, ACCRA 2 THE ATTORNEY GENERAL MINISTRY OF JUSTICE & ATTORNEY GENERAL'S DEPARTMENT MINISTRIES, ACCRA IN THE NAME OF THE REPUBLIC you are hereby commanded within fourteen (14) days after service on you of the Plaintiffs Statement of Case inclusive of the day of service to file or cause to be filed for you a statement of the Defendant's case in an action at the suit of: 1. CITIZENGHANA MOVEMENT NO. 22 GUGGISBERG AVENUE DANSOMAN, ACCRA 2. IMANI CENTRE FOR POLICY AND EDUCATION UNNUMBERED HOUSE, KOANS ESTATES POKUASE, ACCRA Page 1 of3The nature of the reliefs sought is as follows: a. A declaration that the 1* Defendant’s intended implementation of the Common Platform (CP) by connecting Real-Time to the entire switch of the physical network Nodes of the Mobile Network Operators (MNOs) shall constitute an infringement On the fundamental human right to privacy of communication and correspondence guaranteed all persons under Article 18(2) of the Constitution, 1992. b. An order of perpetual injunction against the Defendants restraining them from implementing the Common Platform (CP) by connecting Real-Time to the entire Switch of the physical network nodes of the Mobile Network Operators (MNOs) or in any other way which will infringe on the fundamental human right to privacy of communication and correspondence guaranteed all persons under Article 18(2) of the Constitution, 1992, ¢ An order of Interlocutory Injunction restraining the Defendants, whether by themselves, their servants, workmen, hirelings, agents, privies or any person claiming under or through them, howsoever described from implementing and operationalizing the Common Platform (CP) until the final determination of this ‘suit. d. Any further order(s) as this honorable court may deem fit in upholding the fundamental human right to privacy of communication and correspondence guaranteed all persons under Article 18(2) of the Constitution, 1992. ‘The capacity in which the Plaintiffs are bringing the action is as follows: The 1" Plaintiff is a socio-political organization duly incorporated under the laws of the Republic of Ghana and engaged in advocacy for good governance, social justice and social accountability. The 2 Plaintiff is a policy think tank duly incorporated under the laws of the Republic of Ghana, one of whose objectives is to close the citizenship participation gap in governance through research, advocacy, and independent analysis of public policy. The address for service of the Plaintiff is as follows: 1. CITIZENGHANA MOVEMENT NO. 22 GUGGISBERG AVENUE DANSOMAN, ACCRA 2. IMANI CENTRE FOR POLICY AND EDUCATION UNNUMBERED HOUSE, KOANS ESTATES POKUASE, ACCRA The address for service of Counsel for the Plaintiff i EDDIE MACCARTHY ESQ. LEX PRAXIS INC. NO. 44 KINSHASA AVENUE EAST LEGON, ACCRA Page 2 of 3The names and addresses of Persons affected by this writ are as follows: 1. THE MINISTER OF COMMUNICATIONS. MINISTRY OF COMMUNICATIONS MINISTRIES, ACCRA, 2. THE ATTORNEY GENERAL MINISTRY OF JUSTICE & ATTORNEY GENERAL'S DEPARTMENT MINISTRIES, ACCRA 3. KELNI GVG LIMITED NO. G15, AIRPORT RESIDENTIAL AREA ACCRA DATED AT ACCRA THIS 14™ DAY OF JUNE, 2018. EDDIE MACCARFHY ESQ. SOLICITOR FOR PLAINTIFFS LICENCE NO. GAR 18318/18 LEX PRAXIS INCORPORATED THE REGISTRAR, \WYERS AND ADVISORS SUPREME COURT os ACCRA AND COPIES FOR SERVICE ON: 1. THE MINISTER OF COMMUNICATIONS. MINISTRY OF COMMUNICATIONS MINISTRIES, ACCRA, 2. THE ATTORNEY GENERAL MINISTRY OF JUSTICE & ATTORNEY GENERAL'S DEPARTMENT MINISTRIES, ACCRA KELNI GVG LIMITED NO. G15 AIRPORT RESIDENTIAL AREA ACCRA. Page 3 of 3