We act for Mrs. Amie N.D. Bensouda of Bakoteh, KSMD, The Gambia (hereinafter referred to as “our client”, said Antouman A.B. Gaye & Co. legal Practitioners on Friday May 16 2025.

Our Client’s Background

1. Our Client is a senior Legal Practitioner of 44 years standing in The Gambia and is the Managing Partner of the law firm Amie Bensouda & Co. LP. Our Client’s background includes but is not limited to the following:
   • She is a senior lecturer at the Gambia Law School;
   • A member of the General Legal Council responsible for regulating legal practice in The Gambia;
   • A member of the Chartered Institute of Arbitrators (London).
   • A member of the World Bank Technical Advisory Group for the Land

Governance Assessment Framework (LGAF) in Africa;

• Former Chairperson Action Aid International The Gambia;
• Former President of The Gambia Bar Association (President for two consecutive terms);
• Former Chairperson Institute for Human Rights and Development in Africa (IHRDA).

2. In addition, Our Client presently sits on the boards of and advises several regulated entities and is subject to annual compliance obligations to the Central Bank of The Gambia and under the United States Foreign Account Tax Compliance Act (FATCA). She advises numerous multilateral public bodies that provide significant resources, both in funds, aid, grants etc. to The Gambia and other African Governments.
3. Our Client’s professional relationships require her to meet the highest standards of ethics, integrity, and professionalism at all times.
4. This background is communicated for your awareness (though you are already well aware) that Mrs. Bensouda is a senior citizen of standing, held in high regard both within The Gambia and internationally.

Your Background

5. According to our instructions, you were appointed by the President of the Republic as the Secretary to the Commission of Inquiry ‘(issued under the Constitution of the Republic of The Gambia) to inquire into the financial dealings, assets, and transactions of former President Yaya Jammeh, his family, and close associates (“the Janneh Commission”). You held this position from August 2017 to July 2018. Subsequently, you have been a nominee for election to the National Assembly and a nominee presidential candidate in The Gambia. It is therefore our understanding that you are a well-known person.
6. It is also presumed that you are of sound mental state, and with the ability to reason and distinguish right from wrong. As such, your public statements are presumed to be deliberate, well informed and calculated.
7. The Public Record

7. On the 12th December, 2017 the Commission issued an Order signed by the Chairman with regard to “vehicles and other assets purchased by Ex-president Jammeh from Public funds”. (Copy is attached). The Commission ordered inter alia that:

“3. The Secretary of the Commission shall engage an expert approved by the Commission to assess the status of the rest of the vehicles (including the luxury vehicles mentioned in paragraph I(l)(b) above and their current value, in readiness for their disposal and to also advise on the best way of disposing of same;

4. All vehicles shall be sold under the supervision of the Secretary of the Commission”.
5. From the 23^rd June 2018 you purported to execute the said order and conducted the said sales.
6. On the 26^th June, 2018 you received instructions from the Commission to suspend sales of tractors as a request had been received from the Office of the President that consideration should be given to deprived communities.
7. On the 27^th June, 2018 you wrote to the Chairman wherein you opposed the suspension and complained of political interference. You sought to argue that the sales should not be suspended and that you should be allowed to continue.

1 1 . On the 28^th June 2018t the Commissioners invited you to a meeting at which our client was present as Counsel to the Commission. At the meeting you were queried about the manner in which you handled the sale of tractors and vehicles and dealt with funds received from the sale, including unauthorised expenditures, and sales without reserved prices. You were directed to submit a report with supporting documents. Your subsequent report in fact revealed several administrative lapses and financial irregularities on your part including:

• Failure to bank sales proceeds, • Duplication payments of allowances, e Signatures of persons on daily allowance sheet that were not present,
• Unauthorized expenditures,
• Sales of tractor to Jah Oil Company without a reserve price.

12. A series of correspondence then ensued between yourself and the Chairman which form part of the record.
13. You proceeded to author a memorandum dated 2^nd July 2018 received by our Client on the 3^rd July 2018 which was copied to the President of the Republic, the Chairman and Commissioners, Attorney General and Solicitor Gen-eraVin which you made defamatory statements against our client.
14. In reaction to your memo, our Client wrote to the Attorney General, and Chairman of the Commission copying the President of the Republic as well as yourself. In the said letter our client stated as follows:

“l note that the documents attached to the communications are either part of the exhibits before the Commission tendered on my application or written correspondence between myself and the Commissioners. They are therefore part of the public record I have nothing to hide.

I am saddened by these allegations at a time when such enormous work has been done and the Commission can be said to be winding down. I am of course concemed about the deep-seated resentment and even hatred towards me. I find this alien. I have tried, but failed, to understand how the suspension of the sale of the tractors so that communities’ interest can be considered should warrant such a vitriolic attack on lead counsel.

My concem is that both the communication to me and the communication to the Chaiman copied to me demonstrates a state of mind that, in my view, is inconsistent with the role and standing of the Secretary or the objectives of the Commission. This is a fact-finding Commission, not a crusade against anyone.

I am certain that my legal team and I have conducted ourselves with extreme professionalism at all times. I have had to move significant resources from my Law Fim including personnel, computers and hardware, and provide funding to facilitate the Commission’s work. In fact, Counsel team is doing a significant pan of the work that should ordinarily be done by the Secretary all in a bid to avoid delays and expedite the work of the Commission. I therefore do not believe I have anything to defend or explain and do not intend to enter into any communication with the Secætary on these matters. I have no intentions of being distracted. Let the record speak for itself.

Nevertheless, I do not think it would be in the best interest of the Commission’s work or the national interest for me to continue to work with a person who harbours such negative feelings and perceptions, or who is willing to compromise the truth in pursuit of an uncertain agenda, having regard to the key role we are both supposed to play in the Commission and in the national interest. I am satisfied that since so much attributed to me is untrue, conversations also attributed to others ate equally untrue.

I have given careful thought to the best course of action having regard to my duty to the Commission and the need to safeguard its integrity at all times. I have come to the conclusion that it would not be in the interest of the Commission and the national interest for Mr Kurang and I to continue together in our current roles as Counsel and Secretary. One of us will have to be replaced

An urgent decision on this matter is therefore called for.

Finally, I urge Mr Kurang to desist from further slanderous urges against which I shall not hesitate to take the necessary action”

15. On the 10^th July, 2018 you were relieved of your appointment as Secretary to the Commission.

Your Conduct

16. Despite being challenged to prove your assertions and failing as well as being in receipt of our client’s clear response and unequivocal demand to refrain from further defamatory urges, you have, from the year 2020 or thereabouts, continued to publicly circulate, repeat, restate and reference on social media platforms and formal media interviews the said libelous allegations or derivatives thereof including but not limited to:
    1. Allegations that our client engaged in the sale, or acquisition of assets seized by the Commission;
    2. Claims of conflicts of interest and “shady dealings”;
    3. Repeated insinuations that our client acted with bias or impropriety during the Commission’s proceedings;
    4. Accusations that our client derived or sought to derive personal benefit from her role on the Commission.
17. As a former Secretary to the Janneh Commission, you were fully aware that Counsel to the Commission had no authority or control and played no part whatsoever in the sale, auction, or valuation of assets. As such, our client is of the view, and we agree, that your persistent actions aforesaid were and are malicious.
18. Notably, in your media engagements from 2018 to 2025 you have continued to propagate the same defamatory themes. While you have often avoided direct mention of our client by name, you have coined several monikers and epithets (including but not limited to “mafia”, “Gupta(s)”, “Musukumba”, “corrupt woman”) to specifically identify our client and enable you to persist in a malicious campaign of harassment.

Enclosed is a non-exhaustive list of your defamatory statements.

19. Your veiled references to conflicts of interest within the Commission, corruption in asset sales, and conspiracies to remove you from your post clearly and repeatedly point to Our Client. Your ongoing posts on Facebook (now Meta), combined with innuendo and targeted insinuation, have sought to foster and amplify a hostile and defamatory narrative about our client.
20. The cumulative effect of your sustained seven-year campaign of defamation has caused several other users and social media accounts to echo and circulate these

falsehoods. This has generated unwarranted suspicion in the minds of Gambian citizens that our client was personally involved in the acquisition or disposal of former President Jammeh’s assets, a narrative that is entirely false and contrary to the public record. As a direct consequence of your conduct, Mrs. Bensouda has suffered sustained public questions as to her integrity.

21 . Our client has pointedly ignored your actions for the past seven years but it would appear that this has merely emboldened you and that you have recently resorted to fabricate even more falsehoods about our client’s involvement with the assets seized from Ex President Jammeh, prior to, during and after the Commission.

Our Client’s Claims

22. Accordingly, we demand that you:
    • . Immediately cease and desist from making or disseminating any further defamatory statements concerning Mrs. Bensouda;
    • Permanently remove or cause to be removed any existing defamatory statements from your social media accounts, blogs, or other public platforms;
    • Publish a full and unequivocal retraction and apology in terms to be agreed with us in advance;
    • Confirm in writing within seven (7) days of the date of this letter your intention to comply with the above demands.

• You have seven (7) days from the date of this letter to comply with the demands outlined above. Failing which, legal proceedings will be commenced without further notice in which our client will be seeking injunctive relief, general and aggravated damages for defamation and malicious falsehood in the sum of (One Hundred and Forty Four Million Dalasis).

24. Also be advised that we have instructed legal counsel in London, England, with respect to proceedings against Meta Platforms, Inc., in respect of the defamatory content published from your account and from third-party accounts amplifying your statements. Meta has been formally placed on notice, and further statutory remedies are being actively pursued in connection with the said content published and propagated by you.
25. This letter is written without prejudice to our client’s rights and remedies, all of which are hereby expressly reserved.

Yours faithfully,

File.

STATEMENT