Petition Against the AMCON Receiver Manager In Respect of Block I Plot 1 Victory Park Estate, Lekki, Lagos



Dear Sir/Madam,


It is with utmost humility that I write this petition to your office. Please I humbly solicit your intervention to help investigate and redress AMCON Receiver Manager’s unexplained action to deprive me of the reward of my 30 years working career.


My sincere apologies for sending this petition at this time given the ongoing pandemic situation across the country but I am forced to do so due to the exigency of the matter.



Video OF MALICIOUS DAMAGE TO FENCE AND FENCE MATERIAL BEING HARVESTED FOR SALE



Allegations Against the AMCON Receiver Manager


1. AMCON Receiver Manager is trespassing on my plot of land (Block I Plot 1), located in Victory Park Estate, Lekki, without cause.


2. AMCON Receiver Manager has demolished the perimeter fence on the plot of land, without cause.


3. AMCON Receiver Manager has physically restrained me from progressing construction work on my plot of land for which I have obtained a building plan approval from the LASG, without cause.


Facts of the Matter:


1. I am a law-abiding Nigerian male residing in Lagos Nigeria


2. In 2004, I bought a plot of land in Victory Park Estate, Lekki, Lagos.


a. Completed an application form on 21-June-2004 (Exhibit-1)

b. Given an offer letter on 22-June-2004 (Exhibit-2)

c. Made payment and completed purchase of plot on 22-June-2004. (Exhibit-3)

d. Received initial letter of allocation dated 22-June-2004 (Exhibit-4)

e. Received final letter of allocation dated 27-June-2005 (Exhibit-5)

f. LASG Registered Survey plan dated 15-March-2005 (Exhibit-6)


3. The estate infrastructure was delayed.


4. Developer apologized for the estate infrastructure delay via a letter dated 6-Dec-2006 and communicated that an MOU has been executed with a consortium of banks for financing of estate infrastructure (Exhibit-7).


5. Executed construction agreements with developer dated 12-Dec-2008 (Exhibit-8).


6. Perfected title document (Exhibit-10).


7. Erected perimeter fence and did extensive sand filling of plot of land to the road level (Exhibit-11).


8. Observed trespass on plot of land by AMCON. It was a signage that simply stated that AMCON has taken Possession of the Plot by Order of the Court (Exhibit-12).


9. Had to file a case in court LD/8943LMN/2020 and served all parties. Court papers also placed on the perimeter fence of my plot of land on the 26-Feb-2020 (Exhibit-13).


10. The next day 27-Feb-2020, my perimeter fence was completely demolished by a threatening group of men on the instruction of the AMCON Receiver Manager. The picture of the damaged fence is Exhibit 14 and the Video is Exhibit-15.


11. Following the demolition of my fence, the agents of the AMCON Receiver Manager also harvested and sold materials used for construction of the fence including the steel rods and broken granite slabs (Exhibit-16).


12. On 3-March-2020, I formally reported the demolition of my perimeter fence to the Zone-2 Police headquarters, Lagos (Exhibit-17).


13. It is noteworthy that promoters/bankers did not complete the development of the Victory Park Estate. The Resident Association took up this task for which I have paid a significant part of the N4million levied on me (Exhibit-18).


14. I became aware of some letters from AMCON to the Resident Association in respect of its action in the Estate (Exhibit-19).


15. On 1-June-2020, I reported the matter to AMCON and shared with AMCON my document earlier served on the AMCON Receiver Manager. However, I am yet to get a formal reply from AMCON or its Receiver Manager.


16. Even with the court filing and other actions, the trespass by the AMCON Receiver Manager has continued on my plot (Exhibit-20).



Conclusions:


1. AMCON bought an Eligible Bank Asset (EBA) from a consortium of banks. The EBA was for 14 hectares out of the 50-hectare Victory Park estate. The consortium of banks had alluded to the fact that their interests in the other part of the estate had been sold remaining only the 14 hectares. Exhibit-21 is the estate layout showing the development area likely referenced as the 14 hectares in the EBA.


2. AMCON obtained a court judgement (Exhibit-22) on 3rd October 2017 in the Suit No. FHC/L/CS/744/17 in its favour only for the 14 hectares. The same judgement was referenced in AMCON letters to the resident association of the estate (Exhibit-19). My plot of land again is not covered by the court judgment. The AMCON signage (Exhibit-23) placed on my plot reads: “Possession Taken Over By AMCOM Pursuant to Order of Court” with no reference to a suit number.


3. I bought my plot of land in 2004. This is 2 years before the MOU/Share transfer agreement (Exhibit-24) between the Consortium of Banks and Developer. The plots that had been sold prior to the agreement were acknowledged as existing liabilities or 3rd party interests already established on the land.


4. Why am I being subjected to this action by the AMCON Receiver Manager if AMCON did not purchase an Eligible Bank Asset (EBA) covering my plot if AMCON has no court ruling over my plot and if it has been established that I bought my plot in 2004, which is 2 years before the 2006 financial agreement between the developer and banks.



Petition Prayers


I am just an individual and cannot stand up to the enormous powers and resources of AMCON. I humbly plead with you to investigate the matter and use your good office to address my prayers below on its merit.


1. AMCON Receiver Manager to stop further trespass on my plot of land and remove its signage


2. AMCON Receiver Manager to remedy the demolished fence around my property.


AMCON was created to help stabilize the financial system in Nigeria by efficiently resolving the non-performing loan assets of banks. To accomplish its goals, AMCON has as its core values, Professionalism, Loyalty, Integrity, Fairness/Equity and Excellence. Nigerians hold AMCON in very high esteem and the company should continue to truly embrace its core values and conduct its affairs to high standard beyond reproach.


Please accept the best assurance of my highest esteem for your office and appreciation for your great service to the country. Thank you.


Yours Truly



EmAIL: Eddieagbon@GMAIL.COM | VICTORY PARK ESTATE LEKKI, LAGOS, BLOCK-I PLOT-1



ONLINE PETITION