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THROUGH REGD. AD POST/ COURIER
Dated: 21st^ may 2017
To,
Mr. XYZ D-1 2nd^ Floor, Kalindi Colony, Delhi -
Ref: Your Legal Notice dated 14.05.2017 issued on behalf of your client Mr. XYZ.
Sub: REPLY TO YOUR LEGAL NOTICE DATED 14.05.2017.
Dear Sir, We have been handed over your legal notice dated 14th^ of May 2017, which was issued from your good office to our client namely SONY INDIA PVT. LTD office at A-31, Mohan Co-operative Industrial Estate, Mathura Road, New Delhi-110044.
PRELIMINARY OBJECTIONS:
- That the present claim at the onset is not maintainable as the Noticer did not approach any of the answering opposite parties regarding any alleged defect in the Sony Xperia M2 Dual bearing IMEI No. 353953065369855 (hereinafter referred to as the “ subject handset ”). It is submitted that the subject handset was returned to the Noticer in normal working condition and that the same handset is working perfectly well as the Noticer has not approached the answering opposite parties with the same.
- At the outset, we have instructions to state that your client has not apprised you the correct facts and has also concealed the above stated notice dated 23.02.2013 by our client, which resulted into 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 our client. It is further stated that averments made against our client in the subject notice are wrong, frivolous and misconceived, hence they are denied.
- That the true facts pertaining to the present matter may be noted.
REPLY TO MERITS
- That the contents of Para 1and Para 2 are a matter of record and hence, merit no reply.
- That the contents of para 8 are wrong and denied and as the answering opposite parties have always worked towards the satisfaction of its customers and hence are not liable to pay any amount for the alleged allegations. In reply to unnumbered para of the notice, it is stated that our client has no liability to pay any amount and the subject notice and claim made therein against our client is fictitious and frivolous. It is further stated that any legal or other action initiated against our client by your client shall entirely at your client’s risk, cost and consequences and our 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 against our client henceforth, falling which our client will be constrained to initiate the appropriate legal proceeding and also defend if need arises at the cost and consequences of your client.
Copy of this reply has been retained in our office for future action and references.
ADM and associates
(Advocate)
