To testify on knowledge and authorization of rendition operations, custody conditions, and compliance with legal procedures.

15. [Name Withheld – DSS Officer Involved in Rendition]
To be cross-examined regarding direct involvement in the Defendant’s abduction and illegal transfer, fabrication of witness statements, and custodial abuses.

16. Lt. Gen. Tukur Yusuf Buratai (Rtd) – Former Chief of Army Staff
To testify on the 2017 invasion of the Defendant’s residence and the chain of command authorizing the military operation.

17. Engr. David Umahi – Former Governor of Ebonyi State; Former Chairman, South-East Governors Forum
To testify regarding the proscription of IPOB without judicial order and its consequences.

18. Dr. Okezie Ikpeazu – Former Governor of Abia State
To testify on his knowledge and administrative participation in the 2017 military invasion within Abia State.

19. Sen. Hope Uzodinma – Governor of Imo State
To testify on public statements following Ahmed Gulak’s death and subsequent clarification exonerating IPOB.

20. Chief (Barr.) Nyesom Wike – FCT Minister; Former Governor of Rivers State
To testify on the Obigbo Massacre following the EndSARS protests and the role of security forces under his authority.

21. Mr. Babajide Sanwo-Olu – Governor of Lagos State
To testify on the findings of the Lagos State EndSARS Judicial Panel, particularly the Lekki Toll-Gate massacre, evidencing state pattern of repression.

22. Lt. Gen. Theophilus Y. Danjuma (Rtd) – Former Chief of Army Staff
To testify on his 2018 public warning urging self-defence against infiltrated armed forces, contextualizing the Defendant’s advocacy for self-defence.

23. Mr. Tosin Ajayi – Director-General, DSS
To clarify public lectures and statements advocating lawful community defence against terrorists and invaders, relevant to interpreting the Defendant’s own broadcasts.

PRAYERS AND UNDERTAKINGS
The Defendant undertakes to provide the sworn statements of all voluntary witnesses to this Honourable Court and to notify the Prosecution within a reasonable time.

The Defendant respectfully prays this Honourable Court to issue all necessary summonses and witness warrants under Sections 241–242 of the Evidence Act to secure the attendance of the hostile and adverse witnesses listed above.

The Defendant further prays the Court to note that the appearance of these witnesses is essential to ensuring a fair and complete determination of the issues before the Court.

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