Chibok girls : US court orders $10m service on Wall Street Journal over defamatory publication 

Chibok girls : US court orders $10m service on Wall Street Journal over defamatory publication

By Steve Oko

Reports reaching Wawa News Global says a United States court has granted a $10 law suit against two  leading US newspaper over alleged defamatory publication against a Nigeria rights activist,  Emmanuel Ogebe.

Ogebe confirmed this to Wawa News Global in an electronic mail.

He  said :”United States District Court has ordered the service of a $10 million defamation law suit on two journalists, Drew Hinshaw and Joe Parkinson, through the publishers of the Wall Street Journal, their employer. “

The legal action was instituted by international human rights lawyer Emmanuel Ogebe in response to a defamatory story published by them over his sponsorship of Chibok girls to the US to school.

The court also granted the New York based newspaper extension of time to file their defense to the 40-page libel lawsuit. See excerpts of the lawsuit served on Drew Hinshaw and Joe Parkinson below:

“By such publication, The Wall Street Journal and Hinshaw did cause harm to Mr. Ogebe’s reputation.

Hinshaw and The Wall Street Journal’s publication of these false statements was negligent and malicious at best but it is all too apparent that it was reckless and intentional falsehood as he was never confronted with the key elements.

The e-mail read in full :

“More so WSJ essentially published a sole-source claim by one out of 12 girls but masqueraded as though it were all of the girls. Plaintiff asserts that Ms Bitrus never gave an interview of her story to any media in the US during her 2 years in the program at his behest.

“Plaintiff asserts further that Ms. Bitrus was never in any Nigerian church with the Plaintiff and never time traveled with him in the Mid Atlantic.

7.​At minimum, Hinshaw and The Wall Street Journal should have had serious doubts as to the truth of these statements by the Nigerian government who had an axe to grind, and a high degree of awareness that they were probably false, and therefore were required to investigate their veracity before publishing them and afford Plaintiff a copy for his response. Hinshaw and The Wall Street Journal’s failure to do so amounts to actual malice or at best grievous recklessness.

8.​Hinshaw and The Wall Street Journal purposefully avoided the truth, and premeditatedly avoided public facts such as that the girls who were not lured away from the Plaintiff by Doug Wead’s and the embassy’s ruse remained in school and successfully graduated with diplomas and were all in college at the time of publication. Defendants betrayed fundamental reporting practices intentionally in order to promote lies.

9.​Hinshaw and The Wall Street Journal’s actions were malicious, willful, and wanton, and evidence a conscious disregard for Mr. Ogebe’s rights. Defendants’ publication have hurt Plaintiff Ogebe and his human rights work and his ability to help countless victims who rely on his support. The ripple effect in terms of lives lost is colossal. Accordingly, punitive damages are appropriate.

10.​Hinshaw and The Wall Street Journal’s statements concerning Plaintiff Ogebeare defamatory per se because they attribute to Plaintiff unfitness to perform the duties of his profession, impute criminal conduct and foreseeably would hurt Mr. Ogebe in his profession. Plaintiff is therefore entitled to presumed damages.

11.​The Wall Street Journal, specifically Joe Parkinson, Drew Hinshaw and GbengaAkingbule collaborated to write the article, and were acting within the scope of theiremployment when they published the false and defamatory statements in the article. The Wall Street Journal participated in, authorized, and ratified their conduct.

12.​WHEREFORE as a direct and proximate result of these false statements by Hinshaw and The Wall Street Journal, Mr. Ogebe has suffered damages, including, inter alia, injury to his reputation, embarrassment, humiliation, and emotional distress, in an amount to be determined at trial and Plaintiff Ogebe seeks judgment against the defendants.

              FACTS

Emmanuel Ogebe Dedicates His Life ToAdvocating For Human Rights, Democracy and Assisting Victims

29. The Plaintiff graduated with the best result of his high school class and went to college at age 15, becoming the youngest law graduate in Nigeria as a teenager.

30. In 2003, he was the first lawyer to be admitted to the Washington DC Bar as a SpecialLegal Consultant on Nigeria. He is currently the Managing Partner of USN Law Group, an international legal consultancy firm.

31. The Plaintiff is also an expert on Nigeria and Nigerian Law in the USA and has over the years consulted for various clientele, including government, non-governmental and private organizations on diverse issues relating to Nigeria.​

32. The Plaintiff was consulted by the Clinton White House as well as the second Bush Administration on their respective visits to Nigeria in 2000 and 2003.

33. The Plaintiff was the leader of a delegation from the USA to participate in an African Heads of State Summit on HIV/AIDS hosted by Nigerian President Obasanjo and has at various times met with Nigerian heads of state visiting the US.

34. The Plaintiff also singlehandedly initiated and executed various projects involving humanitarian airlifts to Africa, including but not limited to, the airlifts of about $3 million of medication to Nigeria during President George W. Bush’s visit to Africa.

35. The Plaintiff helped in conducting grassroots economic development, commissioning 400 houses built for victims of flooding in northern Nigeria while undertaking engagements for strategic partnerships with half a dozen state governors to co-fund development projects and networking with international donor and NGO community.

36. The Plaintiff has undertaken humanitarian assistance missions to Nigeria annually for about two decades including providing emergency food aid, medication, computers and clothing from the US to victims in northern Nigeria since 2000 to date. Mr. Ogebe has conducted over 70 of such missions including other African countries.

37. The Plaintiff is the recipient in 2010 of the US President’s Bronze Award in recognition of his pro bono work helping build capacity for NGOs in northern Nigeria.

38. The Plaintiff has represented a man on death-row in Indonesia for over a dozen years pro bono.

39. The Plaintiff is also a prodemocracy and human rights activist who has fought injustice, corruption, dictatorship and advocated change and the enthronement of the rule of law in Nigeria. These activities led him on collision course with various governments in Nigeria particularly, that of dreaded dictator General Sani Abacha, who detained him without trial in 1996. Plaintiff Ogebe was tortured and interrogated about his ties to America.

40. The Plaintiff is a Christian and supporter of several Christian organizations.

41. The Plaintiff has been invited to brief the US Congress on the plight of the people of Nigeria and to plead for the assistance of the United States for the release of the remaining abducted schoolgirls, military and humanitarian assistance to end the killings amongst others.

42. The Plaintiff has advocated at the United Nations, the European Union, the International Criminal Court and numerous other fora advocating consistently on the Nigerian situation. He drew the attention of the ICC to the bombing of the U.N. building in Nigeria by terrorists in one of the worst attacks on the world body.

43. Mr. Ogebe began working toward the eradication of terrorism in Nigeria in 2010, advocating for the release of the “Chibok Girls” and recognition of Boko Haram as a terrorist organization by other nations.

44. Mr. Ogebe’s first human rights advocacy campaign in the US before the New York City Council led to the naming of a corner of E44th street as Kudirat Abiola Corner in honor of a slain prodemocracy activist over two decades ago. She was assassinated by the Nigerian regime and the Nigerian consulate which is located at the corner was opposed to this initiative.

45. From 2014 to the present, Mr. Ogebe and his family have conscientiously, sacrificially and diligently worked for the safety and sound education of these young women, only to be recklessly smeared by the Defendants in an effort to sell their wares and damage his reputation. Mr. Ogebe sold his home to be able to continue supporting some of the gifted and talented young girls who are now in university.

46. On April 13, 2018, The Wall Street Journal published “The American Ordeal of the BokoHaram Schoolgirls” The article, attached as Exhibit A, was published online on The Wall Street Journal’s website and in print. https://www.wsj.com/articles/the-american-ordeal-of-the-boko-haram-schoolgirls-1523661238

47. As a result of the article, Mr. Ogebe’s reputation was irreparably damaged worldwide.

48. Mr. Ogebe has also suffered significant embarrassment, humiliation, mental suffering, and emotional distress as a result of the defamatory article by Hinshaw and The Wall Street Journal.

Hinshaw practices arm-chair journalism by publishing pitched or planted stories on Nigeria

49. Defendant Hinshaw has a penchant for publishing short-turn around stories that are chiefly document downloads from inscrutable single sources. Prior to his publication of the defamatory article, Hinshaw had similarly published a trove of documents purported to be terror communications from Boko Haram. The conduit was ostensibly Jacob Zenn (also gratuitously quoted in the defamatory article). Zenn himself has been accused by fellow academics of strange coziness with Nigerian security services very likely but not acknowledged as the source of the terrorist communications.

50. Prior to that, Hinshaw had published a sizzling report about the ransom negotiations that led to the release of the Chibok girls.  The story shed light on the murky behind the scenes processes. The information was so detailed that it could only have come from one source – Nigerian intelligence services themselves.

51. Unlike the foregoing stories, Hinshaw in this defamatory piece attributed some parts to the Nigerian government although they did not admit that it was a military intelligence dossier from 2015 that had long since been discredited. Given the dubious antecedents of the aforementioned stories, it is increasingly clearer that WSJ and Hinshaw had not unwittingly been spreading propaganda for and on behalf of a foreign government security agency.

52. WSJ created a false urgency for itself in trying to scoop an exclusive and published drivel which other more responsible and sensible media had passed on when pitched to by Doug Wead.

Doug Wead pitches defamatory content to numerous media for three years until WSJ publishes same

53. Doug Wead is the Blackmail Baron who sold Wall Street Journal the bill of goods for this defamatory article even if they willing bought it for free. After Plaintiff had successfully relocated six victims of terror in a US school over the course of a year, Wead was introduced to him by a JUBILEE CAMPAIGN intern as someone they found through Facebook willing to offer additional scholarships for 5 more girls. Unfortunately no prior background check had been done on his antecedents.

54. Doug Wead promptly paid for a press release announcing to the world that his school Canyonville Christian Academy had given scholarships to 10 girls despite the fact that after Plaintiff introduced Wead to the U.S. embassy in Nigeria to confirm his promise, he had been advised against publicizing the girls’ location. Wead also did not have out-of-school housing so Plaintiff was going to have to take care of their off-campus arrangements. Due to the limited language skills of the girls, Plaintiff requested for and received an additional scholarship for an endangered Muslim Background Believer who would be a peer advisor and translator for the other girls.

55. Months after the 5 schoolgirls arrived in the U.S., Wead complained that he had no money and began making financial demands on Plaintiff contrary to his sworn affidavit of scholarships for the girls. Despite collecting a refund for his earlier contributions for the girls’ flights to US, then obtaining a reimbursement for his and his wife’s first class tickets from Virginia where he lives to Oregon where the school is located, Wead on top of that collected an undesignated cash advance which depleted the off-campus care fund for the girls that Plaintiff had established with JUBILEE CAMPAIGN in an unethical and dishonorable bait and switch.

56. Thereafter Wead warned Plaintiff that he would have to raise funds for the girls’ summer break as their spring break was the last Wead would pay for their economy airfares out of the advance he’d collected from Plaintiff’s off-campus care fund. During spring break, Wead then called Plaintiff and informed him that the girls should not return to school but remain in his home and be “home schooled” when Plaintiff declined to have three different TV networks directed by Wead and JUBILEE CAMPAIGN to interview the girls in his home in Virginia. Finally, when Wead refused to let the girls take their flights home for the summer break because Wead’s business associate offered him $300,000 on the condition that the girls spent the summer in his Atlanta mansion, Plaintiff had to report Wead to the FBI.

57. When the girls’ in Wead’s school came bottom last of all 11 girls compared to their classmates in the Virginia school in standardized testing for summer classes which Plaintiff organized, he consulted with a Parent and former teacher of the girls and they decided to make a program decision to consolidate all the girls in the better school. After campus tours with the visiting parent from Chibok, ultimately an even much better school was found and the girls formally transferred.

58. Aggrieved at his lost $300,000 paycheck just from the girls spending the summer in a prospective donor’s Atlanta mansion, Doug Wead began constantly haranguing the Department of Homeland Security, the FBI, and the media to go to the girls’ new school alleging that they had been trafficked. Wead cancelled their health insurance, refused to send their belongings and continued to fundraise online, using a Republican donor database that he acquired, for an entire year while the girls were not in his school and were being catered for by Plaintiff. Wead’s pathological campaign of calumny exacerbated to the US embassy in Nigeria, Senator Rand Paul’s office, Plaintiff’s church, more media outlets who declined and ultimately to the Nigerian embassy in Washington where he found willing accomplices in military intelligence operatives who had been tailing Plaintiff for years over his human rights advocacy on Nigeria. Wead who had engaged in petty blackmail before – accusing Plaintiff of withholding the girls’ passports which was proven false and was never alleged by the girls and then when they transferred sending them the DHS Sex Trafficking Squad’s number to call – upped his game. He accused Plaintiff of trafficking, fundraising, abuse, exploitation, fraudulently bringing in his “relative” to America etc in a dossier which he gave Nigerian military intelligence. This document formed the basis for the Nigerian military intelligence dirty dossier of 2015 which the WSJ published from in 2018.

Nigerian embassy in Washington finds opportunity and tool in Wead dossier for subversive rogue operation against Emmanuel Ogebe to sabotage his human rights advocacy

59. With Doug Wead taking over the fundrasing website meant for the 11 girls exclusively to his school and refusing to stop fundraising even after the visiting parent of one of the girls said to stop, Plaintiff approached the embassy for consular assistance. The change in home government afforded a rapprochement between him and the incumbent ambassador who had a grudging admiration for plaintiff and invited him and the girls for lunch. There embassy intelligence agents bushwhacked the girls and turned it into a hostile and aggressive interrogation led by a Nigerian Air Force Group Captain. They made one of the girls narrate her story and then complained that her English was “too good,” casting doubts that she could speak Hausa (a Nigerian language.) The intelligence agents claimed the girls were fake. The ambassador broke up the interrogation for dinner and photo ops with his guests. Shortly after, the sympathetic ambassador died and the military intelligence had another shot when Doug Wead showed up with the dirty dossier that WSJ ended publishing.

Nigerian embassy’s bogus charges that girls were not really escaped schoolgirls exposed false after secret high-level interrogation

60. After the hostile embassy reception, Plaintiff voluntarily arranged to meet with a high-powered team of Nigerian military intelligence accompanied by one of the schoolgirlsoffsite. They were interrogated and provided the full names and schools of all the girls and the authenticity of the girls was established. A cooperative agreement was reached and another offsite launch meeting was held with several of the girls where their passports were proffered to the intelligence agents who reviewed them and declined offers to take photos of their passports.

61. After that meeting, embassy officials became evasive and began surreptitious visits to the girls’ schools in breach of the cooperative agreement brokered with the high-level intelligence team. Having failed to frame Plaintiff on bogus charges that the girls were not really Chibok schoolgirls, the embassy officials latched onto the Wead dirty dossier for their next offensive.

Nigerian embassy again Targets Emmanuel Ogebe with another failed frame up

62. Following the failed initial frame up, embassy intelligence operatives adopted and adapted the Wead dossier and reframed charges of “fundraising” against Plaintiff and requested the arrest of his family and associates. Unaware of this, Plaintiff voluntarily submitted himself to the high-level intelligence panel pursuant to the cooperative agreement and at that interrogation for the first time heard about the charges which he fully addressed and cleared up with supporting evidence.

63. When the girls’ families informed plaintiff that the girls said they were given a letter by the embassy to sign, and Plaintiff saw that an embassy operative was raising funds online via gofundme with a Nigerian yoga specialist named Somiari Demm ,who falsely claimed to have been taking care of the girls for several years, Plaintiff retained counsel and requested a meeting and investigation by the Ministry of Foreign Affairs.

Nigerian government launches global smear campaign Targeting Emmanuel Ogebe and additional bogus claims.

64. After being busted, the desperate regime unleashed negative reports aimed at the Plaintiff on national network news of the state-owned TV in May 2016. The ministry of Women Affairs began to spread negative news to the media in Nigeria about Plaintiff and Plaintiff began to respond providing evidence.  Officials said Plaintiff beat up the schoolgirls and made them walk to school from his home and back citing the embassy’s dirty dossier but refused to provide it when requested by local journalists. Most did not publish the claims doubting their credibility.

65. In desperation, the regime turned to international journalists. Wead was able to get aNewZealand journalist from a publication he usually used for his political agenda to publish a negative story about the Plaintiff. The journalist who had previously backed off the story when pitched by Doug Wead, picked it up when the Nigerian government threw their weight behind Wead. Although Plaintiff provided her with rebuttal evidence, she refused to use Plaintiff’s evidence if he wouldn’t allow her publish the names of his at-risk local humanitarian workers in Nigeria. That was the first successful hit for Doug Wead and the Nigerian embassy in their joint global campaign of calumny. Some of the girls were picked up from their schools and taken to Wead’s home where they were interrogated for several weeks by Nigerian intelligence agents and urged to give negative statements against Plaintiff but some declined to. Two years later, defendants published the dossier with bigger and better lies.

66. Hinshaw and Wall Street Journal’s allegations against Emmanuel Ogebe are not only clearly false, but they are defamatory per se. By claiming that he threatened the girls that they will be shipped back home where they will be harmed if they didn’t do what he said, Wall Street Journal and Hinshaw attributed to Plaintiff Emmanuel Ogebe -a human rights lawyer and victim-advocate – a willingness to place in harm’s way the very girls whose safety concern prompted him to rescue and bring them to the US in the first place when no one else did.

In fact, journalists and others who exploited the girls’ stories for copy while leaving them in danger, accentuated the risky conditions with the publication of the girls’ pictures, names and locations in Nigeria. In the U.S.,Plaintiff on numerous occasions turned down media requests for interviews with the girls and even requests from VIPs.

67. The girls had refused to return to school in Nigeria till Plaintiff came up with the option to relocate to a safe place. Plaintiff obtained for them 2-year student visas under which by law they were required to return to Nigeria to renew. Defendants’ statement that the girls would be “shipped back” by Plaintiff, was another falsehood as the girls were not in the US on a permanent or refugee basis. Overstaying their visas would actually be a violation of US law. Defendants’ publication prejudiced Emmanuel Ogebe in his profession as an international human rights lawyer and benefactor to survivors and was defamatory per se.

68. The Wall Street Journal and Hinshaw’s highly defamatory and false statements

were not the result of an innocent mistake; they were the result of reckless journalists more concerned with writing an article that fulfilled their contrived narrative about the victimization of these girls handed to him by a dubious, vindictive and opportunistic operative named Doug Wead and a publisher who was more concerned about scoring a cheap scoop on the 4th anniversary of the Chibok schoolgirl abductions, than they were about discovering the truth or actual facts. While truly intrepid journalists were pounding the pavement looking into the whereabouts of the still missing 100 plus schoolgirls, investigating intelligence failures etc., Hinshaw and WSJ settled for bottom-feeder, arm-chair journalism based on a hand-me-down from media-hog and blackmail-baron Doug Wead.

69. Hinshaw and Wall Street Journal acted with actual malice when they published the article.Hinshaw and Wall Street Journal knew that Doug Wead was not a reliable source for truthful information especially given his notoriety for secretly tape recording personal conversations with George Bush to enrich himself by selling a book of those recordings and his crass penchant for shameless self-promotion. Given Doug Wead’s financial interest in the girls raising funds for years even when there were no girls in his school,Hinshaw and Wall Street Journal intentionally violated basic journalistic norms and consciously failed to investigate sources and information that would have revealed the falsity of the charges they leveled other than those spoon-fed to them by Doug Wead. Hinshaw and Wall Street Journal were intent on adopting Doug Wead’s narrative that depicted Plaintiff villainously and Wead as the White Messiah to the rescue. They did this by starting from a conclusion that Plaintiff was callous toward terror victims he brought to America and working backwards to shore up that hypothesis via crafty falsehoods.

70. Defendants imputed to Plaintiff criminal conduct by publishing completely out of context the incidents at the schools were Plaintiff was ambushed on false grounds. Worse, Defendants inquired from law enforcement why Plaintiff wasn’t apprehended implying that he deserved apprehension. This is defamation per se.

71. Hinshaw and Wall Street Journal’s malice is further evidenced by the many half-truths, untruths, and flat out lies Hinshaw and Wall Street Journal told in the publication. Plaintiff did not maltreat the girls. Rather, Plaintiff was called upon to rescuesome of the girls when they were maltreated at the home of an American host family within weeks of their arrival in the US. Canyonville Christian Academy, Oregon did not have holiday accommodations for the girls and its president Doug Wead relied on Plaintiff Emmanuel Ogebe to provide hosts for the girls. Against the express concerns of Plaintiff Emmanuel Ogebe, communicated in writing and in person to Ann Buwalda  of  JUBILEE CAMPAIGN, not to place three of the girls with a dysfunctional American host in Arizona, Ann Buwalda  overruled Plaintiff and put the girls there, where they became subject to lack of adequate food, berating, insults and threats. While Plaintiff was at a Christmas play with his family and some of the other girls in Virginia, he received a series of frantic calls from Ann Buwalda  and ultimately found out she needed his help extricating the three girls from the Arizona home of the rich American woman who was abusing them. Plaintiff had to spend his holiday intervening to keep the woman from dumping the girls on the street, or calling the cops on them or having JUBILEE CAMPAIGN ignominiously ship them back to Nigeria after the American woman falsely accused one of the girls of dressing sexy to entice her husband. Ultimately, Plaintifffacilitated the rescue of the girls from their ordeal in the home of the American woman and evacuated them to the home of a Nigerian family who looked after them and fed them well till they returned to school, thus averting an international incident.

72. JUBILEE CAMPAIGN and Ann Buwalda’s effort to cover up this scandalous incident by paying off  Doug Wead with thousands of dollars meant for the girls’ out-of-school care, her attempt to whitewash the scandalous abuse of the girls in an American home in their first month in America and her poor judgment in taking sides with the abusive American lady simply on account of her wealth, race and connections to a prominent Republican Congressman over the girls, resulted in terminating JUBILEE CAMPAIGN and their affiliate host families. Plaintiff subsequently ran background checks on future hosts who were properly screened professionals and well recommended,thereafter and there were no further problems with the host families he selected. WSJ and Hinshaw’s claims otherwise are false as Plaintiff acted to urgently mitigate an unfortunate situation where the girls were ill-treated on invitation of Ann Buwalda  and JUBILEE CAMPAIGN who themselves created the mess – not a mere “disagreement.”

73. Out of a litany of lies, it is hard to identify Defendants’ most outrageous and disgraceful but this is arguably a top contender. Hinshaw and WSJ falsely claimed that Plaintiff had asked the father of newly abducted Christian schoolgirl Leah Sharibu to bring her to school in the US. Plaintiff had no such conversation with Mr. Sharibu and has never met him. However when Hinshaw and Wall Street Journal did ask Plaintiff about this, one of the few items ever asked of him, he said he had no such plans because he was weary of looking after victims. Subsequently Plaintiff requested Hinshaw and Wall Street Journal to kindly not publish anything concerning Leah who had just been abducted weeks before and was still in captivity as it would endanger her life if Boko Haram heard anything related to her moving to America. As an expert, Plaintiff knew and had testified in congress that Boko Haram executed seven foreign hostages just for hearing media reports that the British were coming to rescue them. Yet Hinshaw and Wall Street Journal published that Plaintiff was planning to take Leah abroad even though she was in captivity which was in reckless disregard for the truth, for Plaintiff’s plea, for journalistic ethics, for humanity and indeed for Leah’s life. The above illustrates Hinshaw and Wall Street Journal’s grave malice that they would even anticipatorily scandalize a futuristic good deed that Plaintiff had not even contemplated and which was not even logically feasible (Leah remains in captivity over 1 year later and it is unclear if she is alive.)

74. Ironically, it was Hinshaw and Wall Street Journal that engaged in a clear pattern of suppression of the truth and active deceit to cover the lies of the schoolgirls whom they knew were of dubious veracity. Plaintiff informed Hinshaw and Wall Street Journal that one of the girls Doug Wead had taken on a visit to the White House to meet President Trump and Ivanka Trump had lied about her story before the United Nation’s Security Council in 2017. The account of one of the Wead girls of her escape from BokoHaram was completely different from what she had said in 2015. Worse still it was an appropriation of the story of another girl whom Wead and the embassy failed to lure away from Plaintiff in 2016. Hinshaw and Wall Street Journal claimed that Plaintiffinstructed the girls to embellish their stories.  However the fact is that in her 2017 testimony before the UN, Doug Wead’s girl lied that it was US Congresswoman Wilson who brought her to the US. Clearly such a lie could not have emanated from Plaintiffwhen it was he himself who brought the girls to the US. This fabrication was obviously concocted by those seeking to delegitimize the kindness of Plaintiff in bringing the girls to the US in the first place. Despite knowing that even the girl’s stories of escape were neither credible nor consistent, Hinshaw and Wall Street Journal still published their stories against Plaintiff maliciously.

75. Hinshaw and Wall Street Journal’s exercise in sophistry, mendacity, deception and falsehood goes beyond the pale. Not only is their malice evidenced by not asking Plaintiff about most of what they published, even when Plaintiff drew their attention to these obvious falsehoods after the fact and submitted a rejoinder, they refused to retract their publication or publish Plaintiff’s response. Plaintiff showed evidence to media in Nigeria that schoolgirl Kauna Bitrus had apologized in writing several years before for her bad behavior and had expressed gratitude and appreciation on behalf of her mother for the opportunity to attend school in America. Plaintiff pointed out that the only intervening circumstances between her apology letter in 2015 and her allegations in 2018 was that she had been receiving thousands of dollars in payments orchestrated by the Nigerian Government which is hostile to the Plaintiff for exposing their human rights abuses. When asked about this evidence in June, WSJ still insisted to inquiring journalists that Ms. Bitrus was truthful and never apologized.

76. Despite knowing that the repressive and human rights-violating Nigerian government had it in for the Plaintiff, was doing all in its power to discredit him and that they girls were on a government payroll, thus raising serious doubts as to their independence, Hinshaw and Wall Street Journal published the defamatory article recklessly.…

PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that the Court enter an award in Plaintiff’s favor, and against Defendants, as follows:

(I)​awarding​Plaintiff Emmanuel Ogebe compensatorydamages of​not less​than

$10,000,000.00;

(2) awarding Plaintiff Ogebe punitive damages of not less than$1,000,000.00;

(3) awarding Plaintiff Ogebe all expenses and costs, including attorneys’ fees; and

(4) awarding an apology to be published in various global media of Plaintiff’s choosing

(5) awarding an injunction restraining defendants from further defamatory publications against the Plaintiff