{UAH} Response to Robukui: how many members

Technically, UNAA has about 150 members.  I say "technically" because UNAA membership is annual (the constitution requires annual payment of membership fees and, to my knowledge, that has been the position held by previous administrations).  About 100 had paid membership in time.  However, Mr Kwesiga unilaterally changed the constitutional definition of a member and turned it from annual to two years.  Therefore, for this year, membership runs from January 2014 to December, 2015.  

Based on that decision above, Mr Kwesiga's administration provided a list of members to the UNAA election commission in September, 2015 and it has about 238 members.  

Interestingly, Mr Kwesiga also claims that UNAA has 1,359 members...at least that is what he is claiming in court.  It is a position his lawyer kept repeating in court on November 30, 2015.

thanks

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On Tuesday, December 8, 2015 at 7:48:32 PM UTC-8, robukui.1 wrote:

How many paid members does UNAA have?

Viele Grube

Robukui

On Dec 7, 2015, at 9:09 PM, "'Joseph Musoke' via Ugandans at Heart (UAH) Community" <ugandans...@googlegroups.com> wrote:

On November 30, 2015, we had oral arguments for the UNAA lawsuit.  The judge asked the parties to defend their positions on our two pending motions:

1. Motion for Judgment on the Pleadings

2. Motion to Supplement the Petition (to add the members' list that UNAA leaders gave to the EC in September).

In my view, the only issue remaining is for us to resolve is the number of members as on November 4, 2014.  UNAA leaders insisted that UNAA had 1,359 members.  However, the list of members that they released to the EC shows just 85 members, 14 of whom were ineligible to vote because they are under 18 or they live outside North America.  In a few days, we are going to show the Court that they are lying about the number of members.  In my view, they are lying to court in a feeble attempt to claim that we had not met the number of members to demand a special meeting.

UNAA leaders filed 3 objections:

1. that our motion to supplement was late because the date for amending pleadings passed in July

    I responded that the order on deadlines was subject to the rule allowing parties to amend their pleadings freely.   

2. that I should not be allowed to represent the Petitioners because I am a potential witness.

    I responded that the rule did not apply to the circumstances because there is jury that would be confused by my dual roles 

    i.e I quoted several cases that show that the rule is mainly aimed protecting juries from confusion.  Judges are capable of     distinguishing my role as a lawyer for petitioners and as a witness.

3. that we should not be allowed to add new petitioners via the supplement. 

    I responded that this objection was misinformed because the court had already allowed us to add new petitioners in     August. At this point, I do not want to add any other petitioners.   

The judge will rule soon about the two motions above.

thanks