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To

1. Managing Director, Pakistan State Oil Company


Ltd. Karachi.
2. Terminal Manager, P.S.O. Ltd. Mehmood Kot.

LEGAL NOTICE

Dear Sirs,

I have been instructed by my client Mr. Sana Ullah, the


proprietor of M/s Malik Motors, Gujjar Khadad, Multan to serve
you with this legal notice inter-alia on the following

GROUNDS

i) That a work order/service agreement 00085 was issued in


favour of my client on 21.1.2002 to provide the transportation
services. It was for the pick and drop of officers and staff
from Multan/Mazaffargarh to Mehmood Kot and back. The
period of this work order was of two years commencing from
1.2.2002 to 31.1.2004. The other terms and conditions were
detailed in the said work order/service agreement.

ii) That my client started the work on 1.2.2002 as per agreement.


My client completed his work upto the satisfaction of your
officers/staff and submitted the bills in this regard on monthly
basis and received the payments till October, 2002, but the
fuel adjustment charges are still outstanding against the
company with effect from 16.2.2002 to 31.10.2002
amounting to Rs. 2,24,919/-.
iii) That my client submitted the bills for the month of
November, 2002 amounting to Rs. 126,900/- on 01.12.2002,
the bill for the month of December, 2002 amounting to Rs.
121,500/- on 01.01.2003 and for January 2003 amounting to
Rs. 23,515/- on 6.2.2003. No payment was made to my client
for these three months and this situation forced my client to
discontinue to provide the services as per agreement dated
21.01.2002. The total payable amount is as under: -

a. Bill for the month of Nov 02: Rs. 126,900/-


b. Bill for the month of Dec 02: Rs. 121,500/-
c. Bill for the month of Jan 03: Rs. 23,515/-
d. Fuel adjustment charges: Rs. 224,919/-

Total: Rs. 496,844/-

iv) That my client submitted many verbal as well as written


requests for the payment of Rs. 496,844/-, but there is no
progress towards the payment of outstanding amounts. You
are hereby requested to pay Rs. 496,844/- within a period of
10 days from the receipt of this notice failing this my client
shall be forced to lodge legal proceedings against you for the
recovery of amount and you shall be responsible for each and
every expense(s) incurred in the litigation.

A copy of this notice is hereby retained in my


office and you are directed to keep this notice with you.
In case of litigation it will be produced by you in the
court. This notice consists of two pages. There is no
cutting, over-writing or omission in this notice.

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