”That I am aware that the 2nd Respondent engaged certain strange heavily built men with dark shades who started tailing my movement around town shortly after 19th August, 2021 when I ended the romantic relationship with the 2nd Respondent.
”That I thereafter became worried that the 2nd Respondent could execute her threats, considering her wide popularity and connection in the Nigerian film industry.
”That at all times material to our romantic relationship the 2nd Respondent always requested and I allowed her to use my Black Colour Lexus SUV LX570 with Registration Number – ABJ 04 JN and Chasis Number – JTJHY7AZ7H4237876. Copies of vehicle documents are attached as EXHIBIT D.
”That upon my return from a trip to Asaba, Delta State around 20th August, 2021 I discovered that the 2nd Respondent had forcefully taken my said Black Colour Lexus SUV LX570 with Registration Number – ABJ 04 JN and Chasis Number – JTJHY7AZ7H4237876 to her residence being House 3A, No. 2, Ismaila Mamman Close, Katampe Extension, FCT-Abuja. Picture of the vehicle is attached as EXHIBIT E.
”That all my efforts to recover the said vehicle from the 2nd Respondent proved abortive as she gave a standing instruction to the security men at her residence not to allow me or my driver access to her residence to recover the vehicle.
”That during my birthday celebration which took place on 27th June, 2021 the 2nd Respondent voluntarily gifted me a Toyota Hilux in the presence of other persons without any papers whatsoever to support transfer of ownership from her to me.
”That because the 2nd Respondent failed, refused and or neglected to hand over necessary documents of the Toyota Hilux vehicle to me I requested her to come and take it back before our relationship turned sour but she gave a deaf ear.
”That I eventually handed over the Toyota Hilux vehicle to Force Criminal Investigation and Intelligence Department (FCIID), Nigeria Police Force with office at Area 10, Garki, FCT-Abuja for onward delivery to the 2nd Respondent. Copy of picture showing the Toyota Hilux vehicle parked at the FCIID is attached as EXHIBIT F.
”That I was however surprised that one Edwin Esq. of FCT Command of the Department of State Services (DSS) with office at No. 7, Gamal Abdel-Nasser Street, Off Julius Nyerere Crescent, Near Kapital Klub and Apartments, Asokoro, FCT-Abuja being under the supervision and control of the 1st Respondent called me and sent a text message vide telephone number 09052460445 on Thursday, 16th September, 2021 inviting me in connection with my estranged relationship with the 2nd Respondent. Screenshot of the text message is attached as EXHIBIT G.
”That the 2nd Respondent caused Kanyi Daily to publicise untrue, fictitious and unsubstantiated story on the same Thursday, 16th September, 2021 vide Kanyi Daily against the person of the Applicant with the caption: “Tonto Dikeh’s Ex-lover, Prince Kpokpogri Arrested By DSS Over Blackmail And Extortion”. Copy of the online newspaper publication is attached as EXHIBIT H.
”That I verily believe that the said invitation by the 1st Respondent is likely targeted at violating my fundamental rights to dignity of human person, personal liberty and freedom of movement, hence my filing of this suit.
”That I am aware that men and officers of the 1st Respondent have been on my trail by tracking my telephone lines and would not give me a breathing space to enjoy my fundamental rights guaranteed under the laws as a free citizen of Nigeria.
”That the 2nd Respondent is hell bent on using men and officers of the 1st Respondent to invite, pester, harass and intimidate me because she is a popular film actress and social media influencer with lots of connections, contacts and followership within and outside Nigeria.
”That it is based on this that I have come before this Honourable Court to seek reprieve, refuge and enforcement of my fundamental rights.
”That this Honourable Court is the last hope of the common man, hence the need for it to compel the 2nd Respondent to tender an unreserved apology to me whilst awarding compensation in the sum of N10,000,000,000 (Ten Billion Naira) in my favour for the mental trauma, emotional stress and severe damage I have suffered as a result of the issues giving rise to this suit.
”That I verily believe that the Respondents herein will not stop conniving to put me in harm’s way through unwarranted, illegal and unconstitutional arrest and detention unless they are restrained by this Honourable Court”.