May 23, 2016
Updated by Manoj Advocate Manoj kumarch. No.362,
Advocatelawyer’s chamber block,
Mobile-[protected]saketdistt. Court, new delhi
Dated:07.05.2016
Speed post/registry
To
1. Jalajakumari. N
W/o sh. Ajay krishnan …noticee no.1
2. Ajay krishnan …noticee no.2
Both at:-kadamnattukoickal,
Kaitha south, chettiikulangara p. O,
Mavellikara, distt. Allapuzha,
Kerala - 690102.
Legal notice
Sir,
Under instructions and authority from my client msheena d/o sh. Kamal r/o model town, delhi, i hereby serve upon you, with thislegal notice of the following contents:
1. That my client is permanent resident of delhi and presently she is doing a private job as a career counselor in a proprietorship concern.
2. That from 29.04.2016 onwards my client started receiving what’s up text messages and calls on her mobile no. (Same is not given here due to her privacy) through mobile no. [protected]/[protected] of you both the noticee wherein you the noticee no.2 firstly sent the pictures of my client downloaded from her facebook account and some other post/complaint with personal details of my client and then started demanding money from my client which was allegedly given by you the noticee to some other
person.
3. That during this late night what’s up conversation firstly you the noticee no.2 tried to extort money from my client and after getting negative response from my client, you the noticee no.2 abused her in filthy language and passed derogatory and cheap remarks/comments on my client without any basis or any provocation and lastly threatened my client of
police complaint and having a support of ten persons with whom you the noticee are having an alleged connivance for the same purpose, due to which my client was forced to block you the noticee from further what’s up conversation.
4. That you both the noticee againthreatened my client as well as the mother of my client; telephonically from 30.04.2016 onwards to defame her in society, facebook friends and all over the world by posting her morphed/doctored photographs online as the pictures of my client have been downloaded from her facebook account by you both the noticee and for the same youboth the noticee has conspired with some unknown persons and thus this way you both the noticee have criminally intimidated my client and further you both the noticee are stalking my client through facebook and what’s up by endangering her privacy as well as her personal life and liberty.
5. That my client further came to know that for getting success in your illegal and mischievous plan of extortion, you both the noticee have shared personal details of my client with some unknown persons and through them you both the noticee have made public the personal details of my client by posting repeated complaints throughbook complaints.com against my client by linking her with some unknown firm/company/proprietorship concern namely man power service or shri man power serviceor skywinfs or skywings etc. Which can be seen by the public at large easily through various links and thus you both the noticee have defamed my client all over the world as a fraud and opened a gate of repeated extortion and threatening calls from unknown persons without any basis to my client and her mother and completely ruined her private life.
6. That my client came to know that you both the noticee are working with some other persons also to get bad name to her by linking the name of my client with more and more fraud companies/ firms for no reason at all and thus you both the noticee have started a bad campaigning against my client without even thinking the future of my client and the impact of the same on the life of my client. So much so that my client is in shock and mental trauma for the internet bad campaigning against my client.
7. That my client is not concerned with the firm/company/proprietorship concern namely man power service or shri man power service or skywings or skywinfsin anyway and you both the noticee in spite of being in the knowledge of the same, deliberately and knowingly maligned and defamed her imageonline and gave her mental harassment just to extract a huge sum of money from my client for no reason at all. Further my client has already published a public notice in indian express dated 03.05.2016 wherein my client has specifically published that she has nothing to do with the above said concern in any way and anyone dealing with that concern shall do at his own risk and perils.
8. That my client has not been in kind of dealing with you both the noticee and she has never met both of you in her whole life and further my client has not taken a single penny from you both the noticee or any
person related to both of you; either in cash or in her bank account and thus she has not done anything wrong with you both the noticee.
9. That it appears that you both the noticee is in a habit of cheating and extorting innocent girls by firstly giving them threating calls and texts of false
police complaint and when you both the noticee doesn’t get any extortion money, then both of you the noticee start defaming them through internet.
I, therefore, through this legal notice, under the specific instructions of my client call upon you both the noticee to remove all the derogatory post/complaints against my client linking her with man power service or shri man power service or skywinfs or skywings or any other firm/proprietorship concern/company from book complaints.com which are easily seen on
google and further desist in future from posting any such above said derogatory post/complaints on any media and further not to stalk my client on any media including facebook and what’s up and to desist from using any photographs of my client on any media in anyway and give an unconditional written apology to my client for all the trauma she has undergone within 3 days of receiving this legal notice, failing which my client shall be at liberty to initiate all the legal remedies civil as well as criminal including cyber cell complaint, defamation suit for rs. 51 lacs, criminal defamation, complaint for stalking and criminal intimidation under ipc, available to her for redress of her grievance against you both the noticee at your own costs and consequences.
You are also liable to pay a sum of rs.11, 000/- towards cost of this legal notice.
Copy retained for further references.
Manoj kumar
Advocate
May 23, 2016
Updated by Manoj Advocate Manoj kumarch. No.362,
Advocatelawyer’s chamber block,
Mobile-[protected]saketdistt. Court, new delhi
Dated:07.05.2016
Speed post/registry
To
Mohammad [protected]@ m. S. Masoori
C/o sh. Jamil khan (Lineman)
35, selawari station road,
Near bsnl office, malhargarh,
Teh.-malhargarh, distt.-mandsaur,
Madhya pradesh, pin-458339 …noticee no.1
Legal notice
Sir,
Under instructions and authority from my client msheena d/o sh. Kamal r/o model town, delhi, i hereby serve upon you, with thislegal notice of the following contents:
1. That my client is permanent resident of delhi and presently she is doing a private job as a career counselor in a proprietorship concern.
2. That on 30.04.2016 my client started receiving what’s up text messages on her mobile no. (Same is not given here due to her privacy) through mobile no. [protected] of you the noticee wherein you the noticee demanded a sum of rs.3, 50, 000/- (Three lacs fifty thousand rupees only) from my client which were allegedly given to my client and for the same you the noticee shared your account vide no. [protected] in
axis bank with ifsc utib0000645 for depositing the above said money of rs. 3.5 lacs.
3. That you the noticee threatened my client of coming to her house with
police and media and further making false
police complaints against my client on the basis of having very good contacts/links with acps and dcps of
delhi police and in the what’s up text sent by you the noticee;very rough and uncivilized language was used by you the noticee for blackmailing and threatening my client for extorting the above said money of rs.3.5 lacs.
4. That you the noticee again repeatedly threatened my client telephonically as well from 30.04.2016 onwards to defame her in society, facebook friends and all over the world by posting her morphed/doctored photographs online as the pictures of my client have been downloaded from her facebook account by you the noticee and for the same you the noticee have conspired with some unknown persons and thus you the noticee have criminally intimidated my client and further this way you the noticee are stalking my client through facebook and what’s up by endangering her privacy as well as her personal life and liberty.
5. That my client further came to know that for becoming successful in your illegal and mischievous plan of extortion, you the noticee have posted a lot of complaints throughbook complaints.com against my client with her personal details by linking her with some unknown firm/company/proprietorship concern namely man power service or shri man power servicewhich can be seen easily through various linkson
google and thus you the noticee have defamed my client as a fraud and opened a gate of repeated extortion and threatening calls from unknown persons without any basis to my client and her mother and completely ruined her private life.
6. That my client further came to know that you the noticee has started to link the name of my client with some more and more companies/firms including skywinfs, skywings etc. And thus you the noticee have started a bad campaigning against my client without even thinking the future of my client and the impact of the same on the life of my client. So much so that my client is in shock and mental trauma for the internet bad campaigning against my client.
7. That my client is not concerned with the firm/company/proprietorship concern namely man power service or shri man power service or skywinfs or skywingsin anyway and you the noticee in spite of being in the knowledge of the same, deliberately and knowingly maligned and defamed her imagethrough internet and gave her mental harassment just to extract a huge sum of money from my client for no reason at all. Further my client has already published a public notice in indian express dated 03.05.2016 wherein my client has specifically published that she has nothing to do with the above said concern in any way and anyone dealing with that concern shall do at his own risk and perils.
8. That my client has not been in kind of dealing with you the noticee and she has never met you in her whole life and further my client has not taken a single penny from you the noticee or any
person related to you; either in cash or in her bank account and thus she has not done anything wrong with you the noticee.
9. That it appears that you the noticee is in a habit of cheating and extorting innocent girls by firstly giving them threating calls and texts of
police complaint and when you the noticee doesn’t get any extortion money, then you the noticee start defaming them through internet.
I, therefore, through this legal notice, under the specific instructions of my client call upon you the noticee to remove all the derogatory post/complaints against my client linking her with man power service or shri man power service or skywinfs or skywings or any other firm/proprietorship concern/company from book complaints.com which are easily seen on
google and further desist in future from posting any such above said derogatory post/complaints on any media and further not to stalk my client on any media including facebook and what’s up and to desist from using any photographs of my client on any media in anyway and give an unconditional written apology to my client for all the trauma she has undergone within 3 days of receiving this legal notice, failing which my client shall be at liberty to initiate all the legal remedies civil as well as criminal including cyber cell complaint, defamation suit for rs. 51 lacs, criminal defamation, complaint for stalking and criminal intimidation under ipc, available to her for redress of her grievance against you the noticee at your own costs and consequences.
You are also liable to pay a sum of rs.11, 000/- towards cost of this legal notice.
Copy retained for further references.
Manoj kumar
Advocate
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