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7 February 2019

To,

Charly Chacko Cherian,

Njakkakalayi, Thelliyoor P O Thelliyoor,

Thelliyoor Pathanamthitta,

Kerala 689544.

WITHOUT PREJUDICE

Dear Sir,

Subject: Legal notice for recovery of money due along with interest
charges.

We write under instructions from and on behalf of my Client,Mr.Shubham Krishna


represented by…………..having office at …………………………………,(hereinafter Commented [V1]: Kindly, insert if there is any authorised
representative
referred to as “My Client”), I address the following notice as follows: Commented [V2]: Kindly, insert the office address .

Our client states and as you are aware, our client is provide services by renting the
motorcycle by way of online bookings. Our client further states that, knowing fully
well about the efficiency of our client and its market reputation, you have
approached our client in Bykemania and requested our client to rent the
motorcycle Royal enfield Himalayan Ka51ab5780 @ Rs. 11,000/month from
Bykemania from dated 28/08/2018 (hereinafter be referred to as “Service”) by
our client to you.

1. Our Client states and you are fully aware that, you have taken the motorcycle
on rent starting from dated 28/08/2018 and you have used the motorcycle for
four months. Our Client further states that, you have made full payment only
for one month i.e; August for the sum of Rs.110000/- by way of cash and
thereafter on dated 9/10/2018 we have received only part payment through
your National Payments Corporation of India (NPCI) account
UPI/828218167936 for the sum of Rs.5000/- and subsequently even for the
next month dated 02/11/2018 we have received a part payment through your
(NPCI) account UPI/830611531562 for the sum of Rs.5000/-. Our client states
that, you have utilized the service for the sum of 44,000/- (i.e; 4 months *
Rs.11000/- per month) but you have made only part payment of Rs.21,000/- to
our client and total sum of Rs.23,000/- is balance from your side.

2. Our Client states and as you are aware, that On 27th December 2018 you have
returned the vehicle to our Client location saying you will do the balance
transfer online in two-three days and you have assured our client by stating
that he could withdraw balance money using the given blank cheque by him
before vehicle delivery to our client. Later when you stopped responding to
our Client we thought of withdrawing the cheque after which we found that
the cheque is already expired.

3. Our client states that you have neither made full payments for availing the
services for 4 Months and neither gave our client a chance to withdraw the
balance sum of Rs.23,000/- from your cheque.

4. Our client also states that, in spite of (i) you being fully liable to pay the
balance amo0unt of Rs. 23,000/- along with appropriate interest to and in
favour of our client, (ii) various emails, reminders, telephonic requests, etc.
sent/ made by our client to you for the immediate and full settlement of your
outstanding dues towards our client and (iii) your acceptance of the said
invoices and your outstanding dues towards our client as well as your various
commitments to fully pay and settle the said outstanding dues towards our
client, you have grossly failed and fully neglected to make payment of the said
sum of monies to and in favour of our client. Our client therefore states that,
your deliberate failure and gross negligence to make the said payment of
outstanding dues along with the interest and your deliberate failure to respond
to several emails, messages, reminders, requests etc. of our client fully expose
your ulterior motives of causing wrongful loss to our client and making
wrongful gain for yourself.

5. Our client states that, in spite of your commitments, assurances and promises,
you have fully failed and deliberately neglected to make any such payment to
our client despite your assurances and promises in this regard and as result, a
sum of Rs.23,000/- still remains unpaid by you, as stated above. Our client
also states that, despite making such promises and assurances, you have
deliberately failed and grossly neglected to pay and settle the outstanding dues
to our client which in fact fully exposes you in respect of your malafide conduct
and dishonest designs by making only bare promises knowing them to be fully
false and without any intention to comply with the same and pay the lawful
dues of our client.

6. In view of the above, our client hereby calls upon you to, immediately and
forthwith, pay and settle within 15 days from the date of receipt of this notice, a
sum of Rs.23,000/-, Conveyances Charges for the sum of Rs.10,000/- and
Legal Charges for the sum of Rs.10,000/- (Total Amount 43,000/-) along
with interest @ 18% per annum from the date on which the said amount
became due and payable to our client till the date of payment, failing which our
client will be constrained to take appropriate legal action, both civil and
criminal, against you as our client may be advised, all at your sole risks as to
costs and consequences.

7. Thus, my Client calls upon you to immediately act upon the requisitions stated
above and compensate my Client for the loss suffered. Further, my Client
states that the contents of this legal notice are without prejudice to the rights
and remedies available to my Client under civil, criminal or any applicable law
in force, and my Client reserves its rights to approach the appropriate legal
forum to take necessary action against you and any party/parties that my
Client deems to be associated with your negligent acts, in any manner
whatsoever.

8. I look forward to your full co-operation with the above stated settlement from
you within 15 (fifteen) days hereof that you shall comply with all the
requisitions set herein above. Should I not receive an appropriate response
from your end to this legal notice within the aforementioned time limit, my
Client reserves her right to initiate suitable legal action against you as they are
best advised, without any further notice to you whatsoever.
Should you wish to discuss this matter, please feel free to contact me at the email
address as mentioned above.

Yours sincerely,

Jeevitha Vetrivelan

Advocate

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