letter

2081 Words5 Pages

My client, is a reputed International Star, the Producer, -the Writer/Lyricist, the Social Activist.(add few of your achievements)

My client had received a notice on January 16, 2014 from you on behalf of Mr Rupesh Paul (the “Notice”). Under the instructions of my client, I am replying to the Notice as follows:

1. That at the very outset my client denies all the allegations and claims by your client under the Notice unless expressly admitted hereinafter. The content of the Notice is completely mala fide, false and fabricated.

2. It is correct that my client had entered in to the Film Acting Agreement with your client on October 27, 2012 (hereinafter referred to as “the Agreement”). In the Agreement, my client had agreed to render her services in the capacity of the solo female lead artiste and to play an Indian Princess role in the film named Kamasutra 3D on non exclusive basis. My client had also agreed to render her services for the promotion of the film. What does 'from top to bottom' mean in the context?

3. Upon your client’s request, even after the wastage of my client’s two sets of dates allotted for the film by virtue of the Agreement she offered 5 dates in the 3rd quarter of 2013 upon being requested to offer 5 dates for the shooting of non-talkie scenes/montages.

4. Upon your client's request, my client made an appearance at the American Film Market in Nov 2013. Upon your client's request, my client made an appearance at the International Film Festival of India in Goa (IFFI) in Nov 2013.

5. It was upon knowing in December 2013, that the entire film was shot in the 3rd quarter of 2013 with a new face as the leading lady of the film who plays an Indian Princess in the film, my client ceased to show any further kindn...

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...d or publishing similar comments in future in any media. Your client is also liable to pay Rs 10 crores to my client towards the compensation and damages caused to her reputation.

33. It is stated that if any proceeding are initiated against my client the same will be vehemently defended at the sole sake of your client as to costs and consequences. Your client is hereby called to within 10 days of the receipt of the reply immediately withdraw the bogus Notice. On the other hand your client is informed that my client reserves right to initiate legal proceeding claiming for the defamatory, derogatory, hurtful comments made by your client against her at a press meet of Kamasutra 3D on January 13, 2014 and series of comments followed by it later. My client also reserves right to initiate arbitration proceedings for the breach of the Agreement.

Yours faithfully,

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