Legal Notice Reply by Rehan Aziz Shervani--Advocate High Court--Cell-0333-4324961
Legal Notice Reply by Rehan Aziz Shervani...
Letter head ================================================ 00.00 2012 Via Courier Without Prejudice
ABC (Advocate High Court) Suite # 340009, 12 Floor, ABC Plaza, 99069-The Mall Road, Lahore th
Reply to the Legal Notice on Behalf of ‘XYZ Solutions’ Sir, With due reverence, reference is had to your legal notice dated December 9, 2012, whereby, your client has tried to lug my valuable client in to spurious; phony; facade frolicsome & illegal snare of assertions. Without prejudice to the generality of the reply and right to contend and quote the incidental and consequential question of law and fact, the reply is as under:: 1.
2. 3. 4.
That ‘XYZ Solution’ is a law abiding organization; never violates the terms and conditions of the contract (s) that it legislates with its counter part (s) or employees. That the organization provides its employees first-rate working environment: affording equal opportunity of professional growth. That the organization does not fall in public sector but a private organization; you are exfacie no body to inspect the business’ legal status. That the business is a legally registered concern under the relevant laws of Pakistan. For posting the phrase: “ So called Company’ we reserve, without prejudice to any other remedy available under the law (s), right to sue Mr. BBB for slander and libel under the Lex Fori of Pakistan’. This highly unbecoming language is really disgusting; nauseating; intimidating & repelling. That no any pressure was ever built, by any one, upon your client; rather he ruptured the good will and repute of the business; for we reserve a right to sue for damages.
That the tour was funded by the organization for two days and extra days cost was agreed to be born by the employees. 7. No personnel ever assaulted your client at the work place; no any mishap occurred and brought in to the notice of the management. 8. No any discrimination, humiliation, favoritism and unethical behavior have ever been extended towards your client. 9. That all the payments etc. have been made to your client; nothing stands payable on the part of the organization. Blackmailing, duress and threats as to shut down the business etc. will be dealt accordingly. 6.
That the organization always pays heed to amicable proposals etc. provided they are logical; consistent; coherent; valid, legal and ethical. Your visit to the office was purely threatening. 10.
That on September 27, 2012 your client was appointed as “Telesales Representative’; the probation period thereof was First Three Months; he tendered his resignation on October 31 , 2012 admitting that the atmosphere/environment at the organization was great & he learnt a lot; the verbatim of his email containing the resignation is reproduced hereunder for perusal and record: 11.
“ I am writing you in order to inform you of my resignation from current position of STR. My last day of working will be effective 31 October 2006. I would like to express my appreciation for your excellent leadership and counsel during the duration of stay at Sachal IT Group. I have learned a lot about skills, how to implement them. Theses skills will be of great value to me in my career. It has been really pleasure for me to work with a great team, with great atmosphere and thank you so much for doing every thing that I have asked from you guys, I cannot even count the favors given by you guys and I really thank you for that. Thanks for every thing.” st
Whatever your client has leveled in the legal notice is contradictory of the above mentioned; stay by the estoppel; it seems as if the legal notice has been designed as to materialize some malevolent designs against the business of the client.
That Mr. BBB’s attitude with the organization has been extorting & intimidating; he has done criminal breach of trust, exercised undue influence, initiated criminal conspiracy to gain wrongful gain from the organization and its employees. Prima facie, there exists no any locus standi in favor of Mr. BBB. The resignation tendered is, ipso facto, contradictory of the allegations leveled in the notice; in limine, Mr. BBB is an offender with accomplices; he has a wrong claim against the organization and its employees; thereto, they jointly and severally, without prejudice to the generality of the above said, reserves right to take stern legal action against him.
For ………… & Company Name: A copy of this reply to the notice is kept in our office for further reference.