COMPLAINT

(Form Mag . 26)

Magistrates Code of Procedure Act Cap 26 S 31

COMMONWEALTH OF DOMINICA

DISTRICT “E”

The 26th day of May 2015

The Complaint of MERVIN JNO BAPTISTE of 12 Great Marlborough Street, Roseau

Who states that:

ROOSEVELT SKERRIT of Vielle Case

REGINALD AUSTRIE of Cottage

RAYBURN BLACKMORE of Mahaut

CASSIUS DARROUX of Kalinago Territory

JUSTINA CHARLES of Grand Bay

KATHLEEN DANIEL of Colihaut

KELVAR DARROUX of St Joseph

KENNETH DARROUX of Petite Savanne

IAN DOUGLAS of Portsmouth

JOHNSON DRIGO of Castle Bruce

COLIN MC INTYRE of Fond Canie

ROSELYN PAUL of Paix Bouche

IAN PINARD of Pointe Michel

PETTER ST JEAN of La Plaine

IVOR STEPHENSON of RiviereCyrique

On the days specified in paragraphs (i) and (ii) below in the district aforesaid did work together to corruptly, directly and/or indirectly influence the results of the Commonwealth of Dominica general elections held on the 08th day of December 2014 by engaging in the unlawful act of Treating whereby:

(i)on the 28th day of November 2014, in Windsor Park Stadium Roseau Dominica in the parish of Saint George and as part of a team of candidates for the Dominica Labour Party in the general election of December 8th, 2014, acting for and on behalf of the Dominica Labour Party provided a free concert with 3 time Grammy Award winner and international gospel star Donny Mc Clurkin to the Dominican electorate at the Windsor Park playing field in Roseau for the purpose of corruptly influencing the Dominican electorate to vote for the candidates of the Dominica Labour Party in the said general election

(ii)on the 06th day of December 2014, in Windsor Park Stadium in Roseau in the parish of Saint George and as part of a team of candidates for the Dominica Labour Party in the general election of December 8th, 2014, acting for and on behalf of the Dominical Labour Party provided free entertainment from International Reggae artiste Morgan Heritage of Jamaica to the Dominican electorate at Windsor Park Stadium in Roseau for the purpose of corruptly influencing the Dominican electorate to vote for the candidates of the Dominica Labour Party in the said general election:

Contrary to Section 56 of the House of Assembly (Elections) act Chapter No. 2:01 1991.

Taken before this day of 28th day of May 2015

(SIGNED BY MAGISTRATE PACQUETTE)

……………………………….

Chief Magistrate/Magistrate

District “E”

FILED: May 28th, 2015

FOR:Aug 31st, 2015