Date: /12/19.

To

Mr. Minhaz.P, Advocate

303,3rd Floor, Dwarkesh Apartment,

Darji Street, Nanpura,

Surat-394510 (Gujarat).

Reference: - Your Legal Demand Notice dated 11/12/2019.

Subject: - REPLY TO YOUR LEGAL NOTICE DATED

11/12/2019.

My Client: - Mrs. Priyanka Gurung, reside at S37/2,

Diamond Harbour Road, KMC, South-Port,

Kolkata-700027.

Dear Sir/Madam,

I am writing to you the reply as under on the instructions of my

above-said client Mrs. Priyanka Gurung who has received a legal notice

issued from your office dated 11th December 2019.

At the very outset, the allegations and averments made in the

notice under reply, unless otherwise specifically traversed and admitted

herein, are strictly denied and refuted. It is stated that your

aforementioned legal notice is without any basis, unfounded and does not

merit any consideration. In this connection my said client wishes to draw

your attention to the following facts considered as preliminary objections:

a) That my client Mrs. Priyanka Gurung is a complete house maker and

does her liability with a traditional means to maintain her family;

she doesn’t have any knowledge about the business of captcha and

outsourcing services at all. I have further instructions to state that

your client has not apprised you the correct facts and has also

concealed the above-stated notice dated 11.12.2019 by my client,

which resulted in the issuance of this frivolous notice. It appears

that your client has misrepresented the true facts deliberately and

has concealed its misdeeds and wrongs done against my client. It is

further stated that averments made against my client in the subject

notice are wrong, frivolous and misconceived, hence they are

denied thoroughly.

b) That the true facts pertaining to the present matter may be noted.

That my client does not even know your client and she don’t have

any business or registered office in the place of 303,3 rd Floor,

Dwarkesh Apartment, Darji Street, Nanpura, Surat- 394510(Gujarat)

and my said client never ever traveled at such place or any

representative has come from that above said place to approach my

client with the offers of making such kind of office.

c) That my client a rational and prudent person; very clearly and best

of her knowledge she didn’t sign any contract or agreement with

your client in her consensus. Your client deliberately and

intentionally misrepresents the fact for the evil purpose of grabbing

the money and making wrongful gains from my client to make this

frivolous story of agreement.

 d) That, however, with due respect we must state that we could not

identify what is your position according to with your letter whether

and when my client appoints you as her advocate or if you tying to

represent a company as their advocate then you didn’t mention the

name of the company in your said letter. We barely found a rubber

stamp (I-TECH) in the last part of your letter dated 11/12/19 and

where you also missed to write down the address of that company.

e) That my client never executed any agreement dated 12/04/2019

with your client on any non judicial stamp paper so basically, she

doesn’t have any knowledge about any terms and conditions

regarding that agreement. If your client produces to you any non

judicial stamp paper where placed the signature of my client then it

simply means that your client trying to transpire the signature of my

client to achieved some illegal means.

f) Vide the above notice, it was also stated that my client is not liable

to make any payment to your client whereas apparently, the

present fact is that your client trying to mislead you with an oblique

motive to mentally harass and blackmail to extort a huge sum of

money from our client through your said notice.

At the outset, it is pertinent to mention here that your client has

concealed the material facts from you thus, has misused your good office

for getting this false and frivolous notice issued against my client.

Moreover, my client also, at the outset, denies each and every averment

made by your client in the notice under reply saves and except what has

been specifically admitted hereinbelow.

PARAWISH REPLY:

1. The contents of Para 1 are dined. My client @ Mrs. Priyanka Gurung

does not have any proprietorship or owned any registered office

with her name in the place of 303,3 rd Floor, Dwarkesh Apartment,

Darji Street, Nanpura, Surat- 394510 (Gujarat). Additionally mention

that my client has not engaged her named with any type of business

of captcha and outsourcing services till now.

2. The contents of Para 2 are very complicated to us to understand

your position as you stated “….our Client is one of the largest and

fastest-growing companies with a vast experience in the concerned

industry and is known for its commitment to its clients…………..its

channel partners & Franchisees to provide its….” Well, doesn’t seem

any problem. But in the very first part you stated “…..under the

instructions from and on behalf of our client Ms.Priyanka Gurung

having…..” so, we have faced a problem to understand your

position, whether you are appointed by my client? if yes then my

client sincerely not accepting this fact or if you advocated or

represent a company as an advocate then it is very unfortunate

response from you that you forget to mentioned the name of your

client who are appointing you as their advocate.

3. The contents of Para 3 are dined. That my client never has a

resident on 303,3rd Floor, Dwarkesh Apartment, Darji Street,

Nanpura, Surat- 394510 (Gujarat), even though she never traveled

at the Gujarat in her life. Additionally my client never approached

your client asking for any kind of “online form filling assignment”
 and she not even enter herself into any kind of agreement on dated

12.04.2019, that time she present in her marital home with his

husband.

4. The contents of the Para 4 are dined. That you have mentioned

about a project named “Data Outsourcing Assignments (captcha)

project ID No.C201904126533”, which is executed on a Non Judicial

Stamp Paper of Rs.100/- with certain terms & conditions in respect

of that mentioned project. My client doesn’t even heard about that

above said project and she doesn’t put her signature on any stamp

paper by accepting the terms and conditions/ Rules and

Regulations which fictitiously made by your client with a evil

purpose to making wrongful gain (read with Preliminary objections

part). Additionally also submitted hereby; how it is possible when

my client present in Kolkata and put his signature at Surat (Gujarat)

on the dated you mentioned as on 12.04.2019?

5. The contents of Para 5 are false and dined thoroughly and my client

not liable to performed any duties and liabilities which are arose

from your client’s fictitious agreement and my client not believed

the story by which your client misled your good office to issuing

your notice dated 11/12/2019. Additionally my client also demand

from your good office the exact copy (scan/photocopy) of that said

agreement which executed on 12/04/19 and valid registration

number and name of the company by whom you good office

represented us.
 6. The contents of Para 6 to Para 10 are false and dined accordingly.

That my client has not entered any agreement with your client so

basically, she has not liable to pay any sum/ short of money to your

client even though your client faced any losses. Your client with a

evil intention to grabbing money from my client by the means of

extort blackmailing and use your good office and trying to mentally

harass my client. Similarly, my client also dined the fact of

communications which your client intentionally fabricating his

allegations, so in this context my client present herself a innocent

and also get immune from any charges for civil as well as criminal

action.

7. The contents of Para 11 and Para 12 are dined under the strict

sense and principal of law. That the allegations which your client

trying to established are completely baseless and by considered all

the facts it is apparently clear that there was no such agreement

was never been took place between your client and my client.

Whereas no question of cheating, criminal conspiracy and criminal

breach of trust as you mention in your letter dated 11.12.2019 are

arose against my client.

In reply to unnumbered Para of the notice, it is stated that my client

has no liability to pay any amount and the subject notice and claim made

therein against my client is fictitious and frivolous. It is further stated that

any legal or other action initiated against my client by your client shall

entirely at your client’s risk, cost and consequences and my client

reserves every right to initiate legal action for damages or other remedies

from your client before appropriate Forum/s, which kindly note.

Therefore, you are requested to call upon your client to withdraw

the above legal notice dated on 11/12/2019 against my client henceforth,

falling which my client will be constrained to initiate the appropriate legal

proceeding and also defend if need arises at the cost and consequences

of your client. Please take a note and advise your client accordingly.

Copy of this reply has been retained in our office for future action

and references.

Yours faithfully,