Joint Investigation Team,
Independence Avenue,
“Very Urgent”
Dear Sir,

Re: Demand for immediate release of 31 unlawfully seized motor vehicles
We have been retained by Broadwaters Executive Motors (Z) Limited(BEM)(our client), kindly therefore note our legal interest herein.

Our client instructs us that on or about 20 March, 2022 at around 22: 00 hours, combined officers from Anti- Corruption Commission, Office of the President, Zambia Police, Drug Enforcement Commission and Finacial Intelligence Center(collectively joint team) entered into property known as Subdivision F of Farm 605 which trades as Moonlight garage and seized 31 motor vehicles. The seized motor vehicles include 13 VX Land cruisers, 10 Toyota Cruiser and 8 Toyota landcruiser Prados. Refer to the attached schedule which lists the specific vehicles with their attendant chassis and engine numbers for ease of identification.

Our client informs us that at the time of the raid, your officers refused to furnish the security guard on duty on the material day ,Mr. Joseph Mulenga, with a copy of a search warrant but rather insisted that they could only talk to the owner of the motor vehicle. Mr Mulenga was further notified that the vehicles were being seized on suspicion that they were acquired from proceeds of crime. Our client further informs us that they vide the said guard, agreed to meet the officers at their office the following day. Your officers further requested our clients to avail them with the documentation relating to the motor vehicles which they agreed. We as a law firm were then engaged for the purpose of engaging your team to resolve the impasse.

However, before the documents could be availed, your officers maliciously issued a statement to the media purporting that the 31 motor vehicles seized were ambandoned and a purported manhunt has since been launched for the owners of the vehicles. This is despite the fact that the vehicles were seized at a known place and your officers were communicated to through the guard as they refused to directly contact our client, the owners. The position adopted by your officers is not only appalling but it is an attempt to prejudice our clients claim on the motor vehicles that they legally procured and imported into the country in accordance with the Customs and Excise Act Chapter 322 of the laws of Zambia. Our client are and were at all material times the bonafide owners of the motor vehicles. We hereby enclose copies of the Bill of lading, proof of payment to the sellers and customs documents as proof thereof.

By reason of the foregoing and in view of the documents duly availed to your office, we have instructions to demand as we do now the immediate release of the 31 motor vehicles to our client.
Kindly note that should you fail to abide by the said demand, we shall proceed and seek legal recourse to which all incidental costs shall be borne by yourselves should you be found liable.
In the interim, kindly acknowledge receipt by signing and returning the accompanying letter hereof.

Yours faithfully

MYM Legal Practitioners
A member of International Bar of Lawyers

C.C Attorney General


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