That the contents of para 1 of your para wise reply are denied as wrong and false and the

contents of
the corresponding para of the legal notice dated 05.07.2019 are reiterated.It is denied that averments
of my client being associated with companies like yahoo, mujra, bio etc. have been made for which
no documentary evidence is presented by my client.
That the contents of para 2 of your para wise reply are denied as wrong and false and the contents of
the corresponding para of the legal notice dated 05/07/2019 are reiterated. It is denied

That the contents of para 3 of your para wise reply are denied as wrong and false and the contents of
the corresponding para of the legal notice dated 05.07.2019 are reiterated. It denied that my client has
surpassed the fact that he had an earlier agreement with the company as held the position of Board
advisor from 10.04.2018 to 31.12.2018. It is denied that that this position was given to my client by
your client as my client had impressed that he was out of a job and desperately needed one. It is
denied that my client during this time also assured that he had successfully exited from his earlier
agreement in a company called C1X before he took the position of Board Advisor. It is denied that
the assurance given by my client was false as his won Linked- In profile shows that he had been
associated with the aforementioned company till October, 2018. It is denied that such omission on
part of my client was made intentionally to deceive your clients and had this been known to your
clients the position of Board Advisor would not have been offered to my client. It is denied that my
client has played fraud upon your clients intentionally.

That the contents of para 4 of your para wise reply are denied as wrong and false and the contents of
the corresponding para of the legal notice dated 05.07.2019 are reiterated

That the contents of para 5 of your para wise reply are denied as wrong and false and the contents of
the corresponding para of the legal notice dated 05.07.2019 are reiterated. It is denied that my client
allegation that he had devoted his entire efforts towards improving the business of the company is
false but the same is in blatant violation of the engagement letter dated 08.02.2019.
It is denied that the sale target of my client for the period of 01.01.2019 to 30.06.2019 was set at 4.40
Crores and my client at the end of June, 2019 was only able to reach 0.40 crores and missed his sales
target hopelessly. It is denied therefore, to suggest that my client devoted his entire effort towards his
job is as absurd as it is thoughtless. Furthermore, it is denied that my client has not brought any
documentary evidence to show that his work was appreciated by immediate superiors.

That the contents of para 6 of your para wise reply are denied as wrong and false and the contents of
the corresponding para of the legal notice dated 05.07.2019 are reiterated. It is denied that my client
is in clear violation of Clause 4 titled Term and Termination of the Engagement letter dated
08.02.2019 as he resigned from his position by way of an email dated 28.06.2019. It is denied that
the important official data relating to the affairs of the company were on my client’s laptop which at
the time of resignation should have been handed over to the company and deleted from my client’s
record as per the Non- Disclosure Agreement. The relevant provision of the Non-Disclosure
Agreement is reproduced hereunder:
“Upon termination of engagement of the receiving party as Board Advisor with the
Disclosing Pasty, for whatsoever reasons, or upon written request of the Disclosing
Party, whichever is earlier, the Receiving Party having received Confidential
Information form the Diclosing Party shall : (i) cease using the Confidential
Information; (ii) promptly return the Confidential Information and all copies, notes, or
 extracts thereof to the disclosing party; (iii) destroy/delete all extracts, analysis,
compilations, studies, summaries, reviews, notes and other material prepared or may
have been copied in course of engagement as Board Advisor by Receiving Party or its
representatives that contain any Confidential information; and (iv) certify in writing that
it has complied with the obligations set forth in this paragraph.”

It is denied that the loss of such data which is the property of company has caused loss to the company
which is being ascertained and shall be intimated by my client.

That the contents of para 7 of your para wise reply are denied as wrong and false and the contents of
the corresponding para of the legal notice dated 05.07.2019 are reiterated. It is denied that my client
did not undergo mandatory notice period of 3 months as per his Engagement Letter on his own
volition reigned by an email dated 28.06.2019. It is denied that furthermore, a proper handover was
required to be given to the company by my client which did not take place and therefore, as already
mentioned in the foregoing paragraph any question of dues, if any, to my client would only be dealt
with after proper hand over is received by your clients from my client.

That the contents of para 8 of your para wise reply are denied as wrong and false and the contents of
the corresponding para of the legal notice dated 05.07.2019 are reiterated. It is submitted that my
client resigned on 28.06.2019 and did not even work till the end the month. As you are aware, the
salary is credited to the account of an employee in the next month and therefore had my client
completed in the month of June, the salary would have been credited in his account in the month of
July. It is denied that since my client whimsically resigned by way of an email on 28.06.2019
therefore, no dues for month of June is owed by your client. It is denied that my client had given in
writing that he would forego his salary for two months as his performance was not upto the mark and
further assured that he would improve in his work. It is denied therefore, that no salary is due to my
client for the month of June, therefore it is incorrect to suggest that my client was restrained from his
employment Agreement as he was unpaid for two months. As far as dues, if any, prior to June, 2019
are concerned, the same shall be dealt as per the Company policy after a proper handover is given by
my client.

That the contents of para 9 of your para wise reply are denied as wrong and false and the contents
of the corresponding para of the legal notice dated 05.07.2019 are reiterated. It is denied that the
conduct of my client has not been upto the high standards as required by the Letter of Engagement.
It is denied that Lack of integrity, gross insubordination and breach of trusts has been highlighted by
my client during his time with the Company. The following shall be considered as far as the instant
paragraph is concerned:-

(a) It is denied that my client’s aggressive behaviour and lack of respect of his subordinates has led
to serious deterioration in the office atmosphere and motivation among the work force;
(b) It is denied that the nature of my client has directly resulted in the loss of an employee working
in the company i.e. Shweta Singh who resigned from the Company on 16.05.2019. Reasons cited
by her resignation email include unprofessionalism and lack of respect shown to other co-workers
by my client.
(c) It is denied that my client is habitual os using unprofessional and indecorous language in the
office due to which many employees have shown disinclination working with my client. It is
denied that despite multiple warnings and counselling my client’s abusive and insulting language
and behaviour, my client did not pay any heed to such which had led to de-motivation in the work
place and also impacted revenues of the company. It is denied that the actions and conduct of my
client has seriously impeded growth of the Company an has caused loss of revenue which is being
ascertained and shall be communicated to my client in the near future as damages.
(d) It is denied that the image created by my client is that of an employee working with complete
dedication and motivation is false.It is denied that my client is habitual of showing lack of effort
and also derelicts duty and has been caught multiple times by his superiors watching videos at
work. It is denied that the actions of my client severely impact the business and revenue of the
Company.
(e) It is denied that my client has perpetrated a fraud upon the company buy changing a invoice of
Rs. 5,90,000/- to Rs. 4,05,000/-. It is denied that when this was note was taken of by your client,
my client wrote a very insulting email to one of the co-founder saying that the entire episode is
‘staged’ against him and also made certain allegations against his juniors and seniors which were
uncalled for and unnecessary. It is denied that when explanation is sought from my client he
immediately changed his stance and said that the only reason accounts department was kept out
of loop in this particular case to safeguard the interest of the company. It is denied that my client
realised that this fraud would soon come into the light so he directed his junior to handle the
matter ‘smartly’ instead of bringing it to the notice of the concerned person.
(f) It is denied that my client in order to save his own skin attempted to shift the entire blame of this
episode to his immediate junior and tried to portray himself as an innocent party to the transaction.
It is denied that my client’ junior confessed to your clients of this fraud, he cited fear of my client
as the reason for this suppression from your clients.

That the contents of para 10 of your para wise reply are denied as wrong and false and the contents
of the corresponding para of the legal notice dated 05.07.2019 are reiterated. It is denied that the
conduct of my client is not upto the mark as per the Letter of Engagement and also my client has not
been able to match his sales target. Therefore, to say that the competence and performance of my
client during the period of company is unquestionable would be correct. It is denied that my client
against the sale target of 4.40 crores only reached 0.40 crores and fell short by quite a margin. It is
denied that my client has also indulged in certain activities which he knew were not in the best interest
of the Company. It is denied that Mr. Sharma was directly reporting to my client and was influenced
by my client into leaving his position at the Company. It is denied that my client even after resigning
from his position was looking into official information to which he already lost his privilege and was
accessing the same by means of Mr. Sharma’s login and password. It is denied that Mr. Abhishek
Sharma and my client were in close collaboration during the subsistence of each works duration in
the company and have collusively undertaken activities which are not in the best interest of the
company.

That the contents of para 11 of your para wise reply are denied as wrong and false and the contents
of the corresponding para of the legal notice dated 05.07.2019 are reiterated. It is denied that your
client is put to strict proof to show that my client’s reputation has been damaged.

That the contents of para 12 of your para wise reply are denied as wrong and false and the contents
of the corresponding para of the legal notice dated 05.07.2019 are reiterated. It is denied that my
client has not been defamed in any manner whatsover by your clients. It is denied that sudden
resignation of my client has caused huge loss of reputation and face with its investors leading to delay
in funding and further operations of the company. It is denied that the loss of revenue attributable to
my client’s conduct and actions have negatively impacted the company’s valuation in the market.

That the contents of para 13 of your para wise reply are denied as wrong and false and the contents
of the corresponding para of the legal notice dated 05.07.2019 are reiterated. It is denied that Rs
15,60,000/- is demanded by my client toward his salary dues is denied out rightly and it is again
reiterated that my client in a hasty manner and on his own accord resigned from his position on
28.06.2019 and did not give a proper handover to the company. It is denied that Rs 50,00,000/-
demanded as damages for defaming my client is concerned, the same is denied as my client has not
been able to prove beyond reasonable doubt nor has produced any documentary evidence to show
any such defamation caused to him and is put to strict proof regarding the same. It is denied that the
legal notice is frivolous and ambiguous and does not disclose any cause of action against your clients.

That the contents of para 14 of your para wise reply are denied as wrong and false and the contents
of the corresponding para of the legal notice dated 05.07.2019 are reiterated. It is denied that no such
amount is owed by your client to my client but on the other hand the loss caused to the Company by
my client shall be borne by my client to compensate the company.

That the contents of para 15 of your para wise reply are denied as wrong and false and the contents
of the corresponding para of the legal notice dated 05.07.2019 are reiterated. It is denied that my
client did not undergo the mandatory notice period, his illegal absence from work has caused the
company loss of opportunity and work.