Reply legal Notice

Sir

Your legal notice dated 25.11.2015 issued to our client M/s.Olympian Entertainment, Rep.by Project Head, A.Bruce Hampson No.28,Vijaya Gardens, Vijayaragava Lane, Vijaya Ragava Road, T.Nagar,Chennai-600 017, have been placed in our hands by our client with instructions to reply as under:1. At the outset broad allegations levelled by your client against our client is utter falsehood and baseless. Your client has concealed the material facts and has also suppressed the ground reality in the event management in order to achieve unjust gains for the best reasons known to your client. 2. Our client instructs that he has been loyal and made such unalloyed dedication, initiative measures because of which the event has taken place at Bangalore. Further our client instructs that due to his acquaintances with prominent members in society and due to his invaluable unalloyed support and contribution, the event was recognised by several jury members, participants and which includes your client too in several instances and circumstances. Further, our client also instructs that it was only due to our client’s management and efficiency the event was successfully staged even after various hurdles which is wholly attributed due to your client mismanagement and as such your client after his consecutive mean and unsuccessful events was unable to get the better and best results has approached our client for managing the event for INDIAN HIP-HOP NATION at Bangalore. 3. Our client further instructs that the allegations levelled against our client is utter false and baseless. Our client instructs that your client was unable to manage the event of his own and has held wrong side of the stick in his past attempts due to his mismanagement, ineptitude and due to his lack of ability and lack of skill your client experienced pungent results was unable

to give successful events independently for “INDIAN HIP-HOP NATION”

4. Our client instructs that, your client being fully aware about his skill level and potential, by masking his flipside and bitter unsuccessful events has approached our client. The prime objective of your client is to have an instant recovery from his mismanaged and ineptitude attempts and to sustain in his business. Further, your client is fully aware that if events are managed by him it would yield stalling results for him.

5. Our client further instructs that neither your client was fully prepared for event requirements nor for the performance requirements on the scheduled day performance i.e on the 30 and 31 Oct 2015. It is also very essential to point out that there was nil preparation till the sunset of 30 Oct 2015 and to be specific your client was totally eclipsed as such he was even unable to intimate and inform the rounds of performance for the participants and to state precise such was the state of affairs that in absence of an performance order, which is mandatory to organise the event our client was told to raise the curtains for the event and being kept in an embarrassed state. Our client with his previous expertise in event management managed the show very successfully.

6. Our client specifically instructs that the invoice dated 03.11.2015 clearly mentions the various expenditure cleared, incurred and paid by our client which has been intimated to your client. Further, as per the terms and conditions agreed and accepted by way of LoA, your client is fully aware about his outstanding dues to our client to the tune of Rs. 4,72,935 with 5% interest per month for delay and default in the payment. Your client’s instructions specifically unveil his attempt to deceive and deprive our client through your notice. It is very clearly evident at the outlook of your notice that in order to cause undue hardship and harassment your client has passed such false, frivolous and baseless instructions, against the ground reality by suppressing the material facts. Your client has deliberately placed a concocted story in order to create an illusionary cause of action

and in turn, viewed from any point of angle has no validity or authenticity.

7. Our client further instructs that, your client remained as mere spectator and the entire management of competition divisions, crew size, age divisions, participation units and their limits, performance area, notification of performers were thoroughly managed by our client. It is also very significant to point out that, your client who is expected to behave in a professional manner and aid in managing the event and performance requirements was only focussed in collecting the participant fees from the participants and even from performance area sponsor who were none other college children of the Mt. Carmel College. Our client further instructs that, due to your client’s couldn’t care attitude the Mt. Carmel College refused to allocate the indoor auditorium as performance area, which they have agreed to spare. Due to our client efforts and intervention at the last minute of the day, the same was reconciled by Adv V GS Narayanan and the college authorities were benevolent to allot the performance area and permitted to conduct the event performances in indoor auditorium. It is very pertinent to inform that, your client has agreed to pay the professional and conciliation fees to Adv V GS Narayanan to the tune of Rs. 50,000/- which is still outstanding. It is also essential to mention that your client that due to illegal and unlawful MoU entered by your client with the college children collectively were participants of minor in age were also represented without parental or guardian consent who were unaware about the event criteria (i.e HIP-HOP crew competition rules and regulations), your client being in default for his act,

kept the

participants and the college authorities in blind manifolds and cornered them by threatening that, he will take appropriate legal action in the court of law. However, your client received a verbal warning from the head of the institution and Adv V GS Narayanan to restrain from such acts while reconciling with the college authorities. Relying on the false promises and assurances made by your client, the innocent college children were finally forced to pay a participant fee even after their noble and benevolent act of granting the indoor auditorium as performance area which exhibits your

client’s inclination for money and who has set aside his objective and purpose as mentioned in your notice. Due to your client unwarranted attitude the college authorities refused to give the indoor auditorium and told to select the performance area in open area and further refused to give power supply for the event. 8. Our client further instructs that, your client again adopted cheap gimmicks with the college authorities that, if the permission for conducting of the event as per the MoU your client threatened that he will ensure that the name of the college would be appearing in headlines for their misbehaviour with the performers and participants. It is not out of place to correctly point out that your client initially pretended that, the entire event is being organised to raise fund for the poor and needy people and as such trusting the commitments made by your client and really being unaware about the cloaked and veiled ill thoughts, behind your client pretending benevolent nature and precedence were made by our client by introducing several sponsors who are noble and philanthropists by nature and for the best reasons known to your client was rejecting all the potential introductions made by our client. Your client started giving evasive replies since the day one after entering into the so called LoA with our client for the best reasons known to him. Our client with no ray of hope as he has entered into the LoA and in order to maintain and secure his name and fame in the society was forced to select the last minute sponsors for the schedule as the event was pretty close. Thus apart from levelling broad allegations by suppressing the material facts which has taken place in Bangalore your client has suggested falsehood for issuance of this legal notice in the course. 9. Our client instructs that, your client without appropriate resources for managing the event held the wrong side of the yard stick and further jumbled the rounds of competition which resulted in placing our client in a converged tunnel view to manage the entire event. Our client even managed such jumbled rounds of competition which were attributed due to your client’s inefficiency and mismanagement and successfully, further

completed the event with all snap and shocking surprises made by your client. It is very significant to mention that, the performance order for the event was prepared but subsequently modified several times by your client to suit your client requirements even after the event was over and by this own act of your client incompetency our client faced hardships and harassment which are unexplainable in words.

10.

Our client instructs that, your client was very

reluctant to that extent that even he was not in position to arrange the basic first aid kit, which is very mandatory in time of any exigencies when the risks and danger involved in the event in known to him as prudent person who claims to be conducting the event in several states. Our client instructs that it came to the limelight of our client that your client NEITHER TOOK PRIOR PERMISSION FROM APPROPRIATE AUTHORITIES FOR BRINGING A PARTICIPANT WHO IS OTHER THAN AN INDIAN ORIGIN nor informed the college authorities in advance in order to take the local police clearance which amounts to unlawful and illegal breach of the so called LoA, and also kept our client unacquainted about the participants who are other than an Indian origin, due to which our client was subjected to undue

stress as the same was demanded by the local police for

permission from the ministry of youth affairs for the participants from outside the country and your client made evasive replies that permission has been obtained and the same is with our client and entangled our client with police authorities. Our client, made personal request that, in future the same would not recur and your client evaded from the scene to escape from the enquiry and till date has not furnished the permission as stated and obtained by him for participation of persons other than Indian origin. It is not out of place to point out that, during the entire event your client kept our client in a slippery state and our client was made to perform an inclined rope walk for managing the entire event on 30 th and 31st October 2015. 11.

Our client instructs that the entire collection of

participation fees was taken by your client and your client started reacting in sceptical and pungent manner after the completion of the event. As such our client is not responsible furnishing any accounts or statements as the same was carried out by your client. Apart from levelling broad allegations towards my client neither my client is responsible for the sum to the tune of Rs. 1,02,300/- claimed by your client nor for the prize amounts as instructed by your client as such your client never stood on ground and took a clean flee from the spot immediately after the event on 31.10.2015.

12.

Our

client

instructs

to,

categorically

and

vehemently deny the allegations levelled in the notice issued on behalf of your client. Further, our client would like to state that the allegations levelled in the notice are nothing but vicious lies and the notice has been issued with a sole object to tarnish and destroy the reputation and standing of our client in the society. The allegations are vicious, false and totally defamatory and levelled with an ulterior motive of embarrassing our client and causing him mental agony and pain. Our client also instructs that the allegations have been made with an intention to create some grounds for your client’s ulterior motive. Our client further informs us that the vindictive and defamatory treatment to him on the days of event cannot be explained in words. Our client also instructs that it is the case of our client that, your client has hurled abuses at our client and disrespected him and embarrassed him in front of his peer group during the event management.

Through this notice, we therefore call upon you to:a. Issue a categorical and unequivocal public apology. b. To clear the outstanding due for the expenditure met by our client to the tune of Rs. 4,72,935 with 5% interest per month. c. To pay the professional and conciliation fees to Adv V GS Narayanan to the tune of Rs. 50,000/If your client fail to comply with the demand made in this notice within 14 (fourteen) days from the date of receipt of this notice, without prejudice to

any other remedy that may be available in law or equity, our client will be constrained to initiate legal proceedings with respect to the outstanding statutory and initiate civil and criminal proceedings against your client in respect of the default in payment, defamation and abuses made by your client. In the event, if your client compel our client to initiate the aforesaid legal actions against your client, your client will be liable for all the costs and consequences thereof.

(G Manimekhalai)