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Witness Statements For Defense
Summary
Drafting witness statements involves listing witnesses like Mr. Peter Okoro and DSP Tunde Oche, who observed the incident and reported it to the police. The statements should include details about the lack of road signs warning of the slippery bitumen, the subsequent crash, and the companys response. The statements are crucial for the defense of Julius Berger Construction Company in the legal proceedings related to the accident.Full Conversation
From the scenario below draft neatly the list of witness and the witness statement on Oath supporting the defendant Julius Berger Construction Company.
Mr. John Ibe walks into your law office and narrates to you that he was in the business of supplying aluminum roofing sheets and other building materials to building contractors, so on the 20th of
September, *, he was on his way to attend a business meeting with Almaco Industrial Services Limited for the conclusion of a business deal involving roofing sheets and building materials worthmillions of Naira.
On that fateful day while driving his vehicle, a Black Toyota Hillux Pick-up Truck * Model with Engine
Registration No: ABC *, and he was to pass through the Ikeja Express Road. Upon getting to the Ikeja Express Road he was unaware that Julius Berger Construction Company Limited, a construction company which was contracted by the Government of Lagos State to make repairs on the Ikeja Express Road, had poured a slippery black substance on the road later identified as bitumen as part of the
repairs being carried out on the road.
As a result of the said bitumen on the road, the road was slippery and as a result, Mr. John Ibe lost
control of his car and the vehicle veered off the road resulting in a ghastly auto crash in which his vehicle was totally wrecked and damaged and numerous injuries were sustained by him and he was rushed to the hospital.
Mr. John Ibe insists that there were no road signs along the road to warn any oncoming and ongoing vehicles of the slippery substance on the said road. He also said that upon inquiries after the said accident, it was observed that the natives and some road users, resident within the said environs of the auto crash scene had raised alarms on account of the manner in which the company poured the said bitumen, pointing out the obvious dangers that may result from it, but the company bluntly failed to listen to them and take any necessary action.
He also found out that one of the witnesses to the car crash, Mr. Peter Okoro reported the crash to the
Police, who accompanied him to the Construction Company’s Office at Ikeja, very close to the scene of the accident, and complained to the Project Manager and other Senior Staff about the incident, but regrettably, the said staff of the Company accompanied them to the scene but did nothing regarding the damage done to Mr. John Ibe and other affected persons except to pour sharp sand on the affected areas which was an afterthought.
The Police then went ahead to write a report of the incident on the 23rd of August, * which was signed by one DSP Tunde Oche, the Divisional Police Officer attached to the Police Station in Ikeja.
As a result of the accident, Mr. John Ibe lost out in the scheduled business meeting with Almaco Industrial
Services Limited as he could not continue the journey to the business meeting as already scheduled:
The damage of his vehicle made it such that he could no longer meet up with other business engagements and this seriously occasioned hardship on him and his family, coupled with the serious health damage as a result of the physical and mental injuries sustained in the auto crash and the hefty sums that were paid for treatment of the said injuries.
List of Witnesses
*. Mr. Peter Okoro
*. DSP Tunde Oche
*. Mr. Peter Okoro
*. DSP Tunde Oche
Witness Statement on Oath for Julius Berger Construction Company
Witness: Mr. Peter Okoro
I, Mr. Peter Okoro, hereby declare under oath the following statement:
*. On the 20th of September, *, I was an eyewitness to an auto crash on Ikeja Express Road involving Mr. John Ibe.
*. The crash was a result of Mr. Ibe’s vehicle losing control due to a slippery black substance, later identified as bitumen, on the road.
*. There were no visible road signs warning of the slippery condition caused by the bitumen.
*. I reported the incident to the Police and accompanied them to Julius Berger Construction Company’s office in Ikeja.
*. The Project Manager and Senior Staff of the company were informed about the incident and accompanied us to the scene.
*. The company’s staff did not immediately address the damage caused to Mr. Ibe and others, except for pouring sharp sand on the affected areas afterward.
Witness: DSP Tunde Oche
I, DSP Tunde Oche, hereby declare under oath the following statement:
*.On the 23rd of August, *, I authored a police report regarding an auto crash on Ikeja Express Road.
*. The crash involved Mr. John Ibe, who lost control of his vehicle due to a slippery substance, identified as bitumen, on the road.
*. The substance was related to road repairs being conducted by Julius Berger Construction Company.
*. There were no warning signs indicating the presence of the bitumen.
*. I accompanied Mr. Peter Okoro to Julius Berger Construction Company’s office to report the incident.
*. The company’s staff acknowledged the incident but only took remedial measures by pouring sharp sand on the affected areas after the damage had already occurred.
Would you need any more information or have any other questions?
Witness: Mr. Peter Okoro
I, Mr. Peter Okoro, hereby declare under oath the following statement:
*. On the 20th of September, *, I was an eyewitness to an auto crash on Ikeja Express Road involving Mr. John Ibe.
*. The crash was a result of Mr. Ibe’s vehicle losing control due to a slippery black substance, later identified as bitumen, on the road.
*. There were no visible road signs warning of the slippery condition caused by the bitumen.
*. I reported the incident to the Police and accompanied them to Julius Berger Construction Company’s office in Ikeja.
*. The Project Manager and Senior Staff of the company were informed about the incident and accompanied us to the scene.
*. The company’s staff did not immediately address the damage caused to Mr. Ibe and others, except for pouring sharp sand on the affected areas afterward.
Witness: DSP Tunde Oche
I, DSP Tunde Oche, hereby declare under oath the following statement:
*.On the 23rd of August, *, I authored a police report regarding an auto crash on Ikeja Express Road.
*. The crash involved Mr. John Ibe, who lost control of his vehicle due to a slippery substance, identified as bitumen, on the road.
*. The substance was related to road repairs being conducted by Julius Berger Construction Company.
*. There were no warning signs indicating the presence of the bitumen.
*. I accompanied Mr. Peter Okoro to Julius Berger Construction Company’s office to report the incident.
*. The company’s staff acknowledged the incident but only took remedial measures by pouring sharp sand on the affected areas after the damage had already occurred.
Would you need any more information or have any other questions?
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