We act for and on behalf of Mrs. Sylvia E.J Blyden, wife of Mr. Babatunde Blyden, both of whom are the Parents of Dr. Sylvia O. Blyden, Publisher of Awareness Times Newspaper.
Our Client has instructed us to write to you in connection with certain articles which appeared in your Newspaper on the 19th April 2011, 20th April 2011 and 3rd May 2011 respectively.
(a) In the Publication of 19th April 2011 at page 14 thereof, under the title,
“SOMETHING TO THINK ABOUT – by Philip Neville,
“She is not the daughter of her Father…”
You stated as follows,
“Among the Journalists in Sierra Leone I consider myself the most appropriate to reply Sylvia Blyden in the Maada Bio’s case and any other one because I KNOW THAT SHE IS NOT THE DAUGHTER OF HER FATHER, and when the time comes if she persists in doing what she has engaged in I will tell the world her true and biological father and why she is behaving the way she is….”
(b) In the Publication of 20th April 2011 at pages 14 and 19 thereof, you repeated the same sub-title
“She is not the daughter of her Father”, and repeated the words set out in (a) above “ipsissima verba.”
(c) In the Publication of 3rd May 2011, at Page 12 thereof, under the title “Something to think about” by Philip Neville, and sub-titled “A Monster goes for excellence award”, you stated as follows;
“….it may be true that her Grandfather SAJ Pratt who is currently an occupant in one of the Old People’s Home in London and receiving handout from the British Government has failed to show and explain the role of certain important people in Sylvia Blyden’s life, like the late Justice Robert Johnson a Regentonian who worked as Master and Registrar of The High Court and was promoted to a High Court Judge and then to a Judge of the Appellate Court and later suffered death in London. Sylvia Blyden would have been proud of this name than what she is roaming the streets of Freetown and addressing herself with….”
It is our Client’s contention that the words complained of in (a) and (b) above, meant and were intended by you to mean that our Client, being a married woman at the time of her daughter (Sylvia’s) birth had committed adultery and that her daughter (Sylvia) had been born as a result of the said adultery by another man, instead of by her biological father, Mr. Babatunde Blyden.
It is further our Client’s contention that the words complained of in (c) above meant and were intended by you to mean that our Client, being a married woman at the time of her daughter (Sylvia’s) birth had committed adultery with the Late Justice William Johnson and that her daughter (Sylvia) was a product of that adulterous relationship, and further that our Client’s father Solomon A.J. Pratt Esq. was aware of the fact of Sylvia being a product of the adulterous relationship between our Client (a married woman) and the late Justice Johnson (a married man) and had not told her (Sylvia) of her true origin.
It is our Client’s contention that all statements contained in (a), (b) and (c) above are a gross and malicious libel, not only imputing (falsely) adultery on the part of our Client Mrs. Sylvia E.J. Blyden (a married woman,) but also imputing adultery on the part of the late Justice Johnson (a married man,) and Conspiracy on the part of Hon. Solomon A.J. Pratt, father of our Client.
We are to state in no uncertain terms that all your allegations are false, unfounded, malicious and cruel in the extreme, not only to our Client and her husband, but also to the family of the late Justice Johnson, none of whom have offended you in anyway.
We therefore hereby, as a first step, demand from you the following:
(1) A full and unqualified apology for, and withdrawal of, the imputations contained in the three (3) Publications of your said Newspaper of 19th April 2011, 20th April, and 3rd May 2011, such apology to be published in a conspicuous part of THE STANDARD TIMES NEWSPAPER, the form of such apology to be submitted to us for approval.
(2) An Undertaking not to continue the Publication of the said statements or any further defamatory statements of and concerning Mrs. Sylvia E.J Blyden;
(3) An Indemnity in respect of such Costs so far incurred, plus a substantial sum for Compensation [so far undetermined,] for the gross and malicious libel against our Client, being a married woman of over 40 years, and the consequent damage to her reputation, character and family, which you so wantonly committed in your Newspaper which has wide local and international circulation on the Internet.
We demand that all above in (1), (2) and (3) must be done within Seven (7) days from the date hereof, failing which we shall be left with no alternative but to issue out a Writ of summons against you with a claim for Punitive and/or Aggravated Damages for Libel.
C.C. (1) Mrs. Sylvia E.J. Blyden ( London )
(2) Mr. Babatunde Blyden ( London )
(3) Hon. S.A.J. Pratt Esq.(London )