23rd September 2019

The Honourable Mr. Marvin Dames, MP
Minister of National Security,
Charlotte House North (1st Floor),
Shirley and Charlotte Streets,
P.O. Box N-3217,
Nassau, Bahamas.

Minister Dames,




I write to you in relation to the ongoing calls from the residents of the political constituency of Mt. Moriah, New Providence Island, The Bahamas, for my return to once again be their Progressive Liberal Party (“PLP”) representative in the Honourable House of Assembly, instead of you.  Those calls have steadily increased over the last 2 years during your current term as their sitting representative.

As I undergo my exploration exercise to get a modern-day handle of the pulse of the constituency, I feel the need to write this “Open Letter” to you for myself and on behalf of my supporters in Mt. Moriah as well as thousands of other good-thinking Bahamians, to call for you to immediately resign from your Cabinet post as the Minister of National Security (includes law enforcement)

We, inclusive of many across the political divide and the Police Force, share abhorrence at your testimony given under oath before Chief Magistrate, Mrs. Joyann Ferguson-Pratt in Magistrates’ Court Case No. 2017/1-17-057025 (intituled Commissioner of Police v Frank Edward Smith).  You admitted to the “witness tampering” of Ms. Barbara Hanna, the virtual complainant in that said action which is tantamount to, if not actually, a crime. Now, inquiring minds want to know how it is that you suffered no consequence when ordinary Bahamians would have faced being jailed for up to 10 years for the same offense.  With such a conviction, you would be constitutionally disqualified from sit as an MP altogether.

We learned on 28th August 2019 that The Bahamas Court of Appeal in Criminal Appeal Action No. 2019/MCCrApp/15 (Intitutled Commissioner of Police v Frank Edward Smith) dismissed the Appeal of the Commissioner of Police represented by the Office of the Attorney General against its attempt to overturn the acquittal of Mr. Frank Smith, so ruled by Chief Magistrate Ferguson-Pratt on 1st February 2019.  URL:

Oddly, Prime Minister, Dr. Hubert Minnis, at whose pleasure you serve in the current Cabinet, does not seem to understand the seriousness of your admission and the need for him to follow the convention of the Westminster system of governance to which The Bahamas subscribes and by which you are compelled to resign, if not fired.   

I believe that your conspiratorial disposition or the setting up of former PLP MP Mr. Frank Smith, begs an in-dept investigation as to the degree of your involvement with certain infamous foreign and Bahamian personalities living in The Bahamas, inclusive of a foreign journalist, Ms. Kim Baker of The New York Times, who has been illegally working here to trump-up fake complaints into falsified criminal charges in a conspiracy to injure me and others connected to a Client of mine, Mr. Peter Nygård, in order to sully my reputation, thereby stopping my return to replacing you as the Member of Parliament for Mt. Moriah.  This appears to be your modus operandi.

Some of your co-conspirators seem to me to have developed interesting ties with you when you served in your unusually short one-year stint as Deputy Commissioner of Police between 2010-2011.  In fact, it is because of your kindergarten pouting for not being named as Commissioner at that time, that I believe led you to resigning that post to become a bodyguard for the infamous Swiss-born businessman of Armenian descent living in Lyford Cay, Mr. Sarkis Izmirlian.  

What I see as your modus operandi in your positions of power, I take as the basis for your blatant lack of remorse for what you have admittedly done to the purported virtual complainant Barbara Hanna keeping in mind that the Chief Magistrate had determined that she had been “…pressured [into giving] evidence against her will…”.  

In upholding the Chief Magistrate’s Ruling, the Bahamas Court of Appeal, in relation to Ground 6 of the failed Appeal of your current Commissioner of Police as argued by the Office of the Attorney General, clearly speaks to your personal “illegality” which, if followed, certainly disqualifies you from sitting in the Cabinet.  For your convenience, the relevant Court of Appeal excerpt from paragraphs 90-93, under the rubric of Ground 6 of their Judgment, is as follows:

Ground 6 – Some material illegality or irregularity, other than hereinbefore mentioned, substantially affecting the merits of the case was committed in the course of the proceedings therein or in the decision.

90. It cannot be said that the Chief Magistrate did not consider the direct evidence of Mrs. Hanna. That evidence would have been foremost in her mind when she went on to determine whether she could place any reliance on it.

91. Mr. Gaskin took issue with comments the Chief Magistrate made after she had given her ruling acquitting the respondent and argued that they demonstrated clearly other matters she had taken into consideration in determining her finding and which clearly displayed bias on behalf of the respondent. He was referring specifically to that portion of the Chief Magistrate’s decision she describes as “an egregious observation”. We need not repeat her observation but we can appreciate the Chief Magistrate’s concern with how the prosecution of this matter progressed bearing in mind Mrs. Hanna’s testimony. We will make reference to some of the aspects of that evidence.

92. Mrs. Hanna testified that before attending the police she had spoken to two Cabinet Ministers, the Minister of Health and the Minister of National Security about this matter but yet she indicated that when she attended Chief Superintendent Rolle’s office, she did not know why she was there. At page 47 of the 29 November 2017 transcript the following appears:

Q. In your mind, who do you think is using you, to your dislike?

A. Well, far as I’m concerned, I can’t say exactly. But I felt that I’m being used, because I’m not the one, who really pursue this matter. And I’m not the one, who went to the police. I felt like I’m being used. That’s my feeling. And I can‘t change the way I feel or how I think about the situation, because I’m not the one who went to the police.

Q.  And you’re upset about it?

A. Of course, I am. I – the police called me in. I didn’t go to them. I were called in. And so, I felt as I’m at a disadvantage in this situation?

Q. Do you remember, when they had called you in?

A. No, sir. I don’t recall, when they called me in. But when they did call me in, I refused to go, didn‘t go. For days I didn’t go. I didn’t go for days. I didn‘t wanted to go.

Q. And then you came under pressure?

A. Yes.

Q. And because of that pressure, you’re here today giving evidence?

A. Yes.

Q. Against your will?

A. Yes, it is.”

93. For reasons outlined in my treatment of the earlier grounds we find no merit in this ground.

From what Mt. Morians are saying, I am of the view that if your behavior is allowed to go unpunished, it would set a bad precedent which can eventually lead to failure of our democracy.

For the reasons set out above and in deference to our Westminster political system of governance to which The Bahamas has subscribed since 1729, I am compelled by my conviction to, as I do so hereby, call upon you to forthwith resign as the Minister of National Security.

Your obstinance from resigning to-date, compelled me to begin a formal PETITION for your resignation from the Cabinet Post as Minister of National Security because of your criminal admission under oath, which exposes you to many years of imprisonment.  

Alas, I fear that your hardheadedness, or ignorance of your duties as a Cabinet Minister, you stand poised to bring the Government of The Bahamas into disrepute, on the world stage.

As such, I hereby do exercise my right and carry out my obligation as an upstanding citizen in our little great Country, to warn you that if you do not tender your resignation from your post as the Minister of National Security on or before Monday, 30th September 2019, I shall be forced to commence aggressive steps of toward compelling you to so do.  This may include going before the Courts of The Bahamas for remedy, without any further warning to you.

You should act accordingly.

Yours sincerely,






Hon. Dr. Hubert Minnis, MP

Prime Minister -Bahamas

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Keod Smith - Keod Smith

Keod Smith is a Barrister in The Bahamas practicing at Commercial Law Advocates, Trinity Place Nassau.

He served as a Member of Parliament for 2002 – 2007 and as Ambassador for the Environment and Chairman of the BEST Commission from 2002 to mid 2006.

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