22
individually and collectively, Intervenors say that it was gross error that they
were not served with any paper or cited to participate in the main proceeding
and would consequently be denied due process as provided for by the
Constitution. And as such, Intervenors have the right to intervene in the main
proceeding; and Intervenors so pray.
7. That Intervenors also say that they will he affected and bound by any
decision that is made by the NEC in the main proceeding. Intervenors further
say that 2 Defendants' claims are similar to theirs as is evidenced by the copy
of a letter submitted by Unity Party, one of Intervenors, to the NEC, dated
October 23, 2017 and submitted on the same October 23, 2017. Copy of the
aforesaid letter is attached hereto as Exhibit "UP-I". And as such, Intervenors
have the right, pursuant to the laws cited in Count Two (2) above, to intervene
in the main proceeding; and Intervenors so pray.
8. That Intervenors further say that their claim have questions of law and fact
in common with the claims of 2nd Defendants in the main proceeding; and as
such and in keeping with the laws cited in count two (2) above, Intervenors
have the right to intervene in the main proceeding; and Intervenors so pray.
9. That as to its specific complaint against the October 10, 2017 elections,
Intervenors pray the NEC to take administrative notice that the Complaint filed
by 2nd Defendants has three (3) main parts; Part 1 being entitled "Violation of
the
Constitution
of
Liberia,
Elections
Law
and
Regulations/Disenfranchisement”; Part II being entitled "Fraudulent Acts'; and
Part III being entitled "Gross Irregularities". Intervenors pray the NEC to take
administrative notice that Part I of the Complaint filed by 2nd Defendants
(Complainants therein) has five (5) sub-sections, as follows: 1. Late Opening of
Polls; 2. Change of Polling Stations; 3. Names of Voters Not Listed on the FRR;
4. The Presiding Officers' Worksheet of the NEC; and S. Absence of Queue
Controllers. Intervenors confirm the facts alleged in the entire Part I of the
Complaint and the principles of law and regulations thereon relied in support
of these averments of fact.
10. That Intervenors also pray the NEC to take administrative notice that Part
II of the Complaint filed by 2nd Defendants (Complainants therein) has ten
(10) sub-sections, as follows: Subsection I being complaint at Precinct #30073;
Subsection 2 being complaint against Presiding Officer, Josephus Cooper;
Subsection 3 being complaint at Polling Place #3, Precinct Code #06102;
Subsection 4 being complaint at Precinct #30121, Polling Place #3; Subsection
5 being complaint against activities at the Collation Center at the SKD Stadium;
Subsection 6 being complaint against activities at Dwazon, Margibi County,
Polling Place #4, Precinct #24105; Subsection 7 being complaint against
activities at Tokpaipolu Public School, Bong County, District #6, Precinct
#06113; Subsection 8 being complaint against activities at Cinta Township,
Margibi County; Subsection 9 being complaint against activities at District #4,
Precinct #06102, Shankpali, Bong County; Section 9 being complaint against
the voter registration card system. Intervenors confirm the allegations of fact
stated in Part 11 of the aforesaid Complaint the principles of law and
regulations thereon relied in support of these averments of fact.
11. That Intervenors pray the NFC to take administrative notice that Part III
(Gross Irregularities) of the Complaint filed by 2nd Defendants (Complainants
therein) has fourteen (14) subsections, as follows: Subsection 1 being
complaint against verification of the number of ballot papers at polling places