8/26/2020 Jupica vs Nec – Supreme Court of Liberia 6. 6. 1st and 2nd Petitioners submit that they have both the legal capacity or Standing to raise these issues or challenge a policy decision of the 1st and 2nd Respondents as a civil society organization dedicated to human rights, rule of law, accountability, transparency, constitutional adherence and reforms, the protection and defense of public interests and social justice and its action and as natural person, a sovereign citizen to challenge the current decisions of the 1st and 2nd Respondents consistent with Article 26 of the 1986 Constitution which expressly states: “Where any person or any association alleges that any of the rights granted under this Constitution or any legislation or directives are constitutionally contravened, that person or association may invoke the privilege and benefit of court direction, order or writ, including a judgment of unconstitutionality; and anyone injured by an act of the Government or any person acting under its authority, whether in property, contract, tort or otherwise, shall have the right to bring suit for appropriate redress…” Your Honor is most respectfully requested to take judicial notice of Article 26 of the 1986 Constitution. 7. 7. Further, 1St Petitioner submits that it brings this action in its own name and on behalf of Edwin K. Martin, a natural person and a citizen of the Republic of Liberia and resident of Paynesville City, Monrovia, because the sovereign power vested in the people of Liberia under chapter 1 Article 1 of the 1986 Constitution is being illegally hijacked, abused and grossly violated for either selfish or pecuniary purposes, a conduct for which 1st and 2nd Respondents have gained notoriety nationally and internationally and petitioners fearing that the Respondents’ actions could jeopardize the current democratic order; are compelled to challenge the authority of both the 1st and 2nd Respondents. Chapter 1 Article 1 of the 1986 Constitution titled: “STRUCTURE OF THE STATE” expressly states: “All power is inherent in the people. All free governments are instituted by their authority and for their benefit and they have the right to alter and reform the same when their safety and happiness so require. In order to ensure democratic government which responds to the wishes of the governed, the people shall have the right at such period, and in such manner as provided for under this Constitution, to cause their public servants to leave office and to fill vacancies by regular elections and appointments.” Your Honor is most respectfully requested to take judicial notice of Article I of the 1986 Constitution. 8. 8. Also, Petitioners say the constitutional expression of: “In order to ensure democratic government which responds to the wishes of the governed, the people shall have the right at such period, and in such manner as provided for under this Constitution, to cause their public servants to leave office and to fill vacancies by regular elections and appointments” as used in Article 1 of the 1986 Constitution solely vests power in the people and only the Liberian people alone can “cause their public servants to leave office and to fill vacancies by regular elections and appointments” and not the 1st and 2nd Respondents who are nothing but mere servants under the Constitution, and their actions to hold elections at all cost being illegal and “void ab initio” constitutionally, Petitioner has both the legal capacity or legal standing to bring this action. comnetitsolutionsinc.org/toj/jupica-vs-nec-2/ 10/27

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