Abolish OSP, empower EOCO for corruption investigation and prosecution with equal terms as OSP

As part of the attempt of the Government of Ghana to combat Corruption and Corruption related offences caused the establishment of the Office of the Special Prosecutor in 2017 under the Office of Special Prosecutor Act 2017 (Act 959). To act as an unqualified independent State Agency for the investigation and prosecution of Corruption and Corruption related offences within the bounds of the 1992 Constitution and laws of Ghana, as well as to take steps to prevent corruption and recover proceeds of corruption and corruption related offences.

The law by my estimation (as a student of Risk Management especially Loss Prevention) is a very bad one because, it implies the OSP, doubles firstly as an Investigator for investigating and Prosecuting when necessary hence a Prosecutor and secondly as a Loss Prevention Manager otherwise Risk Management Specialist at the same time. This is very ridiculous.

OSP performance so far is not encouraging, so OSP should be abolished otherwise it should be reviewed to limit the OSP to function as an Investigating and Prosecuting Agency by divorcing or removing the role of prevention of corruption which is the mandates of numerous parallel institutions like the relevant Parliamentary Sub Committee termed as PAC, Police, the Internal Audit Services, CHRAJ, Office of the Auditor General, Financial Intelligence Center etc,

These parallel Institutions only problem is that they lacked prosecution powers and aside the CHRAJ and Auditor General, the PAC, which enjoy independence, the rest are under the apparent control of the Executive Arm of Government.

The Special Prosecutor allegedly enjoys independence and is to prosecute corruption offence with the authority or permission of the Attorney General in order not to breach provision of Article 88 of the 1992 Constitution. Thus he or she is to do the Constitutional duty of the Attorney General simply because of likely unpatriotic acts by the Attorney General to prosecute a colleague Cabinet Minister.

The reason for the establishment of OSP is therefore absurd, since it was a flimsy excuse that because the Attorney General lacks the appetite or balls to prosecute corruption related offences was Ghana’s reason for the establishment of the OSP and the OSP is required to prosecute under the authority of same Attorney General as stated in Act959 of 2017, who may not have the balls to investigate his colleague, so we have agreed that the OSP was set up to investigate opponents. Cry the Beloved Country.

So, an acceptance that the Attorney General is unpatriotic to deal with acts of corruption against the State as mandated by the Constitution, made Ghanaians or the State to add cost to cost by a wasteful parallel Agency termed as OSP. Thus forgotten that the value is the same, the issue of inertia is expected of both the Attorney General who is to grant authority for the prosecution by the OSP as required by the law and or on the part of the OSP,

Another problem is that by the addition of role of prevention of corruption by the OSP, thus the law allows the Prosecutor to veer off course to areas of Risk Management to encroach the mandate of other parallel Institutions like CHRAJ, Internal Audit Services, and Financial Intelligence Center and the now the Office of the Vice President with his Ghana Card or Digitization and Digitalization to eliminate acts of corruption due to the elimination of human interfaces among other good causes.

It was this other law on prevention of corruption aside the Prosecuting aspect provided under the Act959 of 2017 that Lawyer Hon Martin Amidu exploited for his resignation to cover his shame as the first Special Prosecutor for not able to prosecute successfully a case of corruption . Martin as explained below woefully failed to appreciate that a Risk Management Specialist must discuss his report with the Risk Owner, since the aim of the Risk Management Specialist is to prevent and not to find guilt or entertain suspicion of guilt. So, President Nana Addo was 100 percent right when he asked Hon Martin Amidu acting as a Risk Management Specialist to discuss the Report on the Risk Assessment on Agyapa Royalty with the Finance Minister.

At this juncture, one may ask (1). Why did we fail to reduce cost by expanding the scope of EOCO, to include Investigation and Prosecution of corruption and corruption related offences and strengthening EOCO with the same terms and conditions of security of tenure of office, independence, good budget, the Head and Deputy to be seasoned lawyers of moral character and proven integrity among others as granted to the wasteful OSP. Otherwise (2). Why do we add the role of prevention of corruption to the office of the Special Prosecutor instead of limiting it to Prosecuting, if the reason for setting it up was that the Office of the Attorney General lacks the appetite or the balls to prosecute Corruption and other offences as granted under Article 88 of the 1992 Constitution.

The OSP by my judgment, is just a wasteful venture, job for the boys and girls because Ghana has numerous anti-Corruption Agency including the CHRAJ, the Police, PPA, EOCO, Office of the Auditor General, internal Audit Services, Financial Intelligent Center, BNI, etc, some of these like stated above on EOCO need to be fine-tuned.

Once again let me add that the law on the OSP as stated is a very bad one similar to the bad Small Scale Mining Law which is ambiguous because with the Small Scale Mining Law, Parliament woefully failed to separate Small Scale Mining or Galamasey or Community Mining for rural folks from Medium Scale Mining for tycoons like Chairman Wontumi is the reason for the massive destruction of the environment.

As stated, in one of my submissions on the menace of Small Scale Mining, Parliament should have maintained the PNDC Law 218 of 1989 for Small Scale Mining. Google for PNDC Law218 of 1989 on Small Scale Mining for the wisdom of the originators of this law which a JJS pupil can tell as a Galamasey Law (that was for the Legalization and Formalization of Galamasey which tells it all under section 21 on interpretation).

As stated in my paper and as agreed with me by Dr Tony Aubyn, one time CEO of Minerals Commission and CEO of Ghana Chamber of Mines, Parliament should have created another Classification in the Mining Sector as Medium Scale Mining, for tycoons like Chairman Wontumi to operate under a separate law from the law on Small Scale Mining. This would have allowed the creation of Ghanaian billionaires by allowing Ghanaian to freely do joint partnership with foreigners like Chinese etc with similar terms and conditions similar to those of Large Scale Mining Companies under auspices of the Ghana Chamber of Mines.

Enter the OSP, firstly, let me say that Lawyer Kisi Adjebeng like my brother Lawyer Martin Amidu is a very good material for combating Corruption but unfortunately, due to a problem and the nebulous law of the OSP, he may not be able to prosecute the offences related to corruption, as desired of Ghanaians and the people of the world at large to reduce corruption to the barest minimum.

The OSP has operated for more than seven years yet the level of corruption is reportedly increasing. This therefore suggests that no effective approach and results by the OSP and this may be due a possible security agenda by the proponents otherwise no more appetite by the proponents especially the politicians, hence their seemingly unsupportive acts or posture, and or the possibility of inertia on the part of the OSP.

The seemingly unsupportive posture of the proponents for the established of OSP suggests that they had/have a different intention of a hidden agenda of a special purpose vehicle to deal drastically with the OPPONENTS, otherwise a decoy/campaign gimmick to demo that Corruption is being fought against.

So, the way things have unfolded so far, with Ghana as a crime scene for corruption that is corruption permeated or permeated everywhere hence on the increase, could make a critical minded person to buy the opinions that the OSP may be a special purpose vehicle to deal with opponents and a decoy/a campaign gimmick to demo that Corruption is being fought against.

The speed at which the OSP was established that is within one year on taking over by the proponents from the previous regime of the NDC and the appointment of Hon Mr Martin Amidu, who earlier on portrayed that he has something against some of his fellow party folks of the NDC party’s Stable or persons in the previous regimes of the NDC, hence a seemingly henchman, may validate the above perceptions that the intention was/is for dealing with opponents and or a decoy/a campaign gimmick to demo that Corruption is being fought against.

This state of affairs, could give a person of a critical mindset a reasonable cause to believe that the OSP is just a decoy and the proponents had the hope or thought that the OSP under the leadership of Hon Martin Amidu will deal drastically the opponents of the current regime (which happened to be the proponents for the OSP) based on the philosophy of my enemy is your enemy. Hence, the statutory tenure of office is seven years and is nonrenewable so that the proponents may have another chance to nominate a favourable surrogate another henchman for the next seven years if Martin ends his tour.

Fortunately or unfortunately (depend on where one stands) the performance of Hon Martin Amidu was a gross failure or below expectation and did not exhaust the nonrenewable seven years tour of duty as the first Special Prosecutor due to resignation. So to cover the shame, Hon Martin Amidu cleverly conducted risk assessment on the plan for the Agyapa Royalties which is also within the mandate of the OSP that is to take steps to prevent corruption or possible acts of corruption. A role same as the realm of Risk Management Specialist or Risk Expert or Loss Prevention Officer to alert or educate an Organization or a Manager etc of the associated risks in the Organization or an operation etc and the appropriate risks control measures to be implemented by the Manager or Risk Owner to mitigate the risk to the barest minimum.

So, Martin knowing very well that the President of Ghana as the Risk Owner of the planned Agyapa Deal would ask him to discuss his Risk Assessment report as expected with the then Minister of Finance, as the secondary risk owner of the Agyapa deal as well as fully armed with the intelligence of the Ghanaian trademark of Pull Him Down, he cunningly threw dust into the eyes of the public about corrupt acts by President Nana Addo and thus courted the support of his Compatriots to run amok with this allegation due to our usual cacophonous Court of public opinion to help defend his resignation from the OSP.

Surprisingly, some Intelligentsias, seasoned Security Expects, Seasoned Lawyers, CSOs who should know better but due to reasons best known to them, woefully failed to appreciate that that the ultimate aim of risk assessment is to identify the associated risks in an operation and come out with the Control Measures and discuss same with the Risk Owner. So, instead of educating the public on what was expected of a Risk Management Specialist or Expert, a role played by Hon Martin Amidu, they rather bought Hon Martin Amidu’s allegation of corruption against President Nana Addo.

The Agyapa or the Minerals Royalty is a very good deal if and only if we are able to identify the likely risks which may be associated with it and do the right thing. So, if it is properly done, it would help bring massive improvement in the economy of Ghana including generating millionaires among the shareholders who will invest their yields in other areas to create more jobs, pay taxes, and bring more development. So, we need to wake up from our slumber and act accordingly.

It is therefore recommended that the new Minister of Finance or the next Administration effective January 2025 be it NPP or NDC (the NDC should be credited as the first to come out with the Gold Royalty Deal concept) should reintroduce the deal and seek Stakeholders engagement to fine tune the Gold Royalty concept (Agyapa Royalty) so that Ghanaians can also buy shares when the shares are floated in the London Stock Exchange and the Ghana Stock Exchange to demo the proper ownership of the minerals as decreed by the framers of the 1992 Constitution with the provision of Section 6 of Article 257.

Thanks to God for Hon Mr Martin Amidu for his seemingly godly acts, due to his uprightness, so when as the first Special Prosecutor, he did not behave like the current Special Prosecutor by letting the OSP to waste funds in logistics and underserved compensations for some of his Investigators, allegedly as his friends who were formerly of the rank of Security Superintendent in the State Security Services and who have been wrongly granted with the rank of COP. The rank of COP is almost same as that of the IGP who is COP1. One therefore cannot ruled out element of inducement, hence seemingly acts of corruption related offence by Lawyer Kisi Adjebeng

Lawyer Kisi Adjebeng knew or knows very well that the best way to fight corruption is to get very good and seasoned Investigators with moral character and proven integrity is by either to ask for persons on secondment or open up with advertisements in the appropriate media for global applicants especially from the BNI, Police, Financial Intelligence Center, EOCO etc or use both method to get investigators and not pick his friends, coworker or Client when he was lawyer.

So, the act of recruitment of some of his Investigators may appear to any person with a very critical mindset that it is within the domain of acts of corruption and or Corruption related issues (include favoritism for a possible hidden agenda), consequently, this act should be condemned by honest Ghanaians especially the Intelligentsias and the relevant CSOs if they worth their salts.

Lawyer Kisi Adjebeng, Hon Amidu Martin’s successor’s fishing expedition and veering off course that is navigating outside the jurisdiction of the OSP’s Law, especially working on suspicion of Money Laundering just to convict a suspect herein Hon Cecilia Dapaah at all cost or to heighten public condemnation of the Witness namely Cecilia Dapaah under his investigation is unethical. This conduct is an act unbecoming of a Prosecutor/Investigator or against Best practices as expected of a competent Prosecutor and an Investigator. This must be condemned by all good thinking persons especially Ghanaians.

Best practices required that the witness or suspect should be informed the specific allegation he or she is being investigated and given the chance to respond and the Prosecutor must stay on course. So after the Investigator has gathered all the information and evidences/exhibits to solve a crime, the details are reviewed and analyzed to come out with findings, so, that the Investigator will reach a well-reasoned conclusion based on the preponderance of the evidence standard that is whether it is more likely that the alleged conduct did or did not occur.

Furthermore, the Prosecutor shall not initiate or continue or shall not make every effort to stay proceedings, when an impartial investigation shows the charge levelled against the Witness or Suspects to be unfounded. That a Prosecutor must refrain from prosecuting a charge that the Prosecutor knows is not supported by probable cause or predicated case.

Also, best practices require that a Prosecutor must ensure that the evidence sought is essential to the successful completion of ongoing investigation or prosecution and will not divulge same to the public except for statements that are necessary to inform the public of the nature and extent of the Prosecutor action. The Prosecutor shall share intelligence with legitimate Anti-Corruption Agencies and or law enforcement Agency and refrain from making extrajudicial comments that have a substantial likelihood of heightening public condemnation of the suspect or witness.

Likewise, a Prosecutor should not allow interest in personal advancement, or aggrandizement to affect judgments regarding what is in the best interest of justice in a case. Lastly, the prosecutor should not make, cause to be made or authorize or condone the making of, public statements that the Prosecutor knows or reasonably should know will have a substantial likelihood of heightening public condemnation of the suspect or Witness.

Enter Cecilia Dapaah’s case and the OSP, occupied by Lawyer Kisi Adjebeng Esq, as the Special Prosecutor, who was appointed to the OSP in 2021 for the restricted job for investigation and prosecution of Corruption and Corruption related offences, among others as provided by the Office of Special Prosecutor Act 2017 (Act 959). In July 2023, Investigators from the Ghana Police Services came out with a Police charge sheet No D4/155/2023 for prosecution of two persons reportedly as staff of Hon Mrs Cecilia Dapaah.

They were accused by Hon Cecilia Dapaah for the theft of some cash stashed in her residence. Especially an alleged sum of 800,000.00 United State Dollars and left behind 200,000.00 US Dollars, this total sum of One Million US Dollars reportedly belong to her deceased brother and the theft of GHC300,000.00 as contribution for her mothers’ funeral contained in a box. There was a public outcry against the news of stashing in a residence of a sitting Minister of State for the Ministry of Sanitation and Water Resources with a large sums of money with some in foreign denominations especially US Dollars when the Nation was seeking for more dollars to arrest the galloping depreciation of the value of the Cedis to the Dollar.

It was felt or suspected that the cash sums were tainted with acts of Corruption and or Corruption related issues that is to say the proceeds came likely from corruption and corruption related offences. So in line with the mandate of the OSP that is Regulation 6 of the Office of Special Prosecutor (operations) Regulation2018 (LI2374) caused the OSP under Lawyer Kisi Adjebeng to trigger a genuine investigation on 24 July 2023 into the relevant offences, whilst the Police continued with the criminal aspects as complained by Lady Cecilia Dapaah.

Consequently as legally required, Cecilia Dapaah was placed under arrest by the OSP on charges of suspected corruption and corruption related offence. This was followed with a search at her residence which led to the discovery of 590,000.00 US Dollars and GHC2,730,000.00. So in accordance with section 32(1) of the Office of Special Prosecutor Act 2017(Act 959), the OSP exercise seizure of the sums which she and the husband were required to tell the source.

There were various funny stories including the mistaken belief that some of the money might have come to her as a bribe likely from a Company which was earlier on contracted by the Government of Ghana under the auspices of the Sanitation Ministry under her watch to desilt drains or to conduct drainage around Nkrumah Circle etc. So this concoction, or state of affairs unleashed the gullible public, Media Houses and some CSOs to assassinate the character of Hon Cecilia Dapaah day and night 24/7.

The OSP, accordingly conducted extensive investigation into the case and no crime of corruption etc as permissible by law to be handled by OSP was/could be established by the OSP against Lady Cecilia Dapaah. Since no substantial evidences were deduced to sustain the charges being handled by OSP in the area of the offence of Corruption etc which prompted the arrest of Hon Mrs Cecilia Dapaah, seizure of the cash in her residence for investigation and subsequent prosecution if ok.

With no acts of corruption established against Hon Cecilia Dapaah, it was therefore expected of the Special Prosecutor Lawyer Kisi Adjebeng to demo that he is a professional Prosecutor or Investigator by exercising his discretion and close the case docket and if armed with any intelligence on or if he suspects of other crime not within his mandate, simply alert the relevant mandated Agency to act accordingly, that is if deemed necessary without initiating an investigation deep into an offence of possible money laundering which the OSP is precluded by law to work on but he did so extensively.

Thus armed with an intelligence of possible or suspected money laundering, the Special Prosecutor should have halted the investigation and alert EOCO to initiate investigation into it. Unfortunately, the Special Prosecutor arrogated himself with the powers to investigate Transnational or a cross border crime of money laundering, so he proceeded and spent time and money to visit the FBI at its Headquarters in USA and got them to assist in an investigation not predicated on any offence.

By an act of veering off course, Special Prosecutor Kisi Adjebeng, acted unethically, unfairly, illegally when upon realizing that no acts of corruption committed by Cecilia Dapaah and veered off course on 23 October 2023 and investigated a case of suspected money laundering which is a Transnational or cross border and trans boundary or organized crime within the mandate of EOCO.

Annoyingly, Lawyer Kisi Adjebeng went further to court the support of FBI and continued with the investigation on the suspected money laundering or organized crime for four months, This was so, due to a claim by a witness of Cecilia Dapaah in her statement that part of the seized cash or cash with Cecilia amounting to 200,000.00 US Dollars was transported from USA to Ghana by courting the support of fellow passengers to accept to carry some of the cash with them, which they did and the cash was retrieved on arrival in Ghana.

As a seasoned Lawyer, lawyer Kisi Adjebeng knew or should have known very well that by operation of law, EOCO has the specific and direct mandate on cases of money laundering/cross border crime. So it is not surprised that after 4 months of investigations into likely money laundering offence, the Special Prosecutor hit a wall in his work and shamefully wanted the EOCO to take up with the investigation into an offence of money laundering not predicated on an offence. Because, he wants to humiliate Cecilia he woefully failed to appreciate that the Offence of money laundering was not committed by Cecilia Dapaah in person, it was by a third party, Cecilia did not commit offence to be handled by the OSP, if it was/is clear that the cash involved in her custody possibly came to her through money laundering, and not about corruption as provided by the law on the OSP to handle.

So on fishing expedition to jail or humiliate Lady Cecila Dapaah, he delayed on closing the case of corruption etc by November 2023 until on 24 January 2024 that the OSP discontinued the case of corruption in Court and the Court ordered the return of the cash etc and unfreezing of Cecilia’s bank account within 72 hours.

On 25 January 2024, referred Hon Cecila Dapaah’s case to EOCO that is after the OSP unlawfully trespassed the jurisdiction of EOCO and wasted money and time and at end he wants to make EOCO as a Client of OSP.

It is most disturbing that the Special Prosecutor could not tell from his investigation that Hon Cecilia Dapaah cannot and will not be called upon to answer for a suspected crime of money laundering. The Witness who reflected how she brought the money into Ghana in her statement should be the one may be charged for money laundering and Cecelia would be used as a prosecution witness

If so, to prosecute the case of money laundering to achieve what aim if not to humiliate Cecilia Dapaah? Especially when the witness of Hon Cecilia Dapaah had succeeded in smuggling the money found with Hon Cecilia Dapaah, which was made or earned from work or otherwise in USA into his home country to help develop it. Just like Tetteh Quarshie did for his Country when he smuggled cocoa to Ghana and accordingly regarded as hero of Ghana. This makes the overstretching of the Cecilia Dapaah case as unacceptable of a Prosecutor. No sound Investigator with discretionary powers will buy this.

Surprisingly due to our national brand of PHD (Pull Her Down) despite the fact that the Special Prosecutor has proclaimed that no offence of corruption as initially perceived was established against Hon Cecilia Dapaah we (Ghanaians) including seasoned lawyers, Intelligentsias etc continued with the assassination of the character of Cecilia Dapaah. A clear manifestation of the Ghanaian PHD syndrome.

This situation, may be due to political interest and thus clouded our mindset and made all of us (the Compatriots of Cecilia Dapaah) looked on stupidly and resulted in the illogical clapping for the Special Prosecutor by some of us when he openly told us that he was going to court the support of the FBI to assist in investigating on a matter which common sense may suggest to us that is an offence of money laundering, which even a JSS pupil is fully aware that money laundering is outside the jurisdiction of OSP.

So it is abundantly and unequivocally clear that the OSP under a seasoned Lawyer Kisi Adjebeng as the Special Prosecutor, seemingly allowed interest in personal advancement, or aggrandizement to affect his good judgment on matters regarding what is in the best interest of justice when he veered off course to an offence of money laundering which is a forbidden jurisdiction to the OSP, this may be due to an attempt to continue to humiliate Cecilia Dapaah.

So, we need to ask Lawyer Kisi Adjebeng, the Special Prosecutor that if he could not get substantial evidence against a crime related to his mandate as in Act 959 of 2017 against Cecilia Dapaah and instead of keeping a new suspected crime not committed directly by Cecilia Dapaah secret (on need to know basis) why should he continue to motivate the general public to continue to be condemning Cecilia Dapaah and somebody as the Witness of Cecilia Dapaah, who reportedly smuggled some dollars from USA to Ghana to help improve our economy if the offence committed is not predicated on a case.

Lawyer Kisi Adjebeng as a Special Prosecutor must be educated that but for Mr Tetteh Quarshie who smuggled cocoa from Fernando Po to Ghana, and thus made Ghana to be depending on the yearly robbing Peter to Paul economy by way of the yearly ritual of the cocoa syndicated loan which has boosted the Cedis in the past and is still helping to boost the Cedis, Ghana would have been suffering in abject poverty.

Lawyer Kisi Adjebeng as Special Prosecutor and his cohorts must be told that Hon Cecila Dapaah did not commit any crime in keeping the monies in her residence. One may only say that she was not patriotic. They must learn that there was no way our fellow Ghanaian by name Miss Mona Faiz Montrage alias Hajia 4Real could have banked all the over Four Million US Dollars, she allegedly received from her scam romance in the Transnational or Cross Border crime which would have triggered investigation by the Financial Intelligence Center and or EOCO, so the possibility of her to have kept or keeping some dollars at home was/is high. Food for thought. A deduction that they are lots of Cecelia Dapaahs in the system.

Furthermore, from the archives, in April 2018, some members of Winners Chapel Ghana allegedly kept cash of over 200,000.00 USA Dollars in car tires and smuggled the cash out of Ghana to the parent church or the Headquarters in Nigeria. So a lot of things are happening behind the scene or at the blind side of security personnel or with the support of Security personnel at the Ports and Borders.

Let me add that Ghana Government at one time smuggled out over one million dollars from Ghana to pay players of Black Star. So money laundering or smuggling is in our National psyche. Hmm, I ever smuggled over 10,000.00 Dollars into Ghana from Congo being allowances made from UN operations in Democratic Republic of Congo, when I found that the fees charged by my bank namely Stambic Bank, with branches in Kinshasa and Accra was not good.

So, I had to take the risk with my Diplomatic or Green passport and when I landed at Brazzaville Airport, I had the support of two corrupt Immigration Staff at Brazzaville Airport in Congo Brazzaville, who collected Fifty Dollars bribe from me and gave me intelligence on how to escape from being searched by Immigration and the scanner in Abidjan Airport. Truly with the intelligence from them, I was able to outsmart the Immigration and the scanner or screening machine at Abidjan Airport when I landed on transit waiting for a plane to Accra.

At this juncture, let me salute EOCO under the leadership of COP Maame Tiwa Addo Danquah, (coincidentally she was at one time, one of my students at Bompata Secondary School) for exercising a sound discretion and an independent judgment of a Prosecutor or Investigator as per best practices to also see the interest of a witness and respect the constitutional and legal rights of the Witness or suspect.

It should be noted that the Prosecutor as part of administration of justice and officer of the Court, his or her primary duty is to seek justice within the bounds of the law and not merely to convict. Hence, the Prosecutor should exercise sound discretion and independence of judgment in the performance of the function of investigation and prosecution and should consider the interest of the witness and respect the constitutional and legal rights of the Witness or suspect.

Let me conclude by saying that OSP is a wasteful venture, a parallel Institution to EOCO, CHRAJ, Internal Audit Services, Office of Auditor General, BNI (NIB), Financial Intelligence Center etc so we just added cost to cost or job for the boys and girls. OSP should therefore be abolished.

We should rather expand the scope of EOCO to include investigating and prosecuting the offence of corruption and corruption related offences. To ensure good delivery by EOCO, the mandate of EOCO should be strengthened by granting EOCO, same terms and conditions of services as granted to OSP especially unqualified Independence, secured tenure of office say not less than seven years which should not be renewable etc and appoint seasoned lawyers with moral character and proven integrity as the Head and Deputy.