Legal Notice

Acnuo PlRrNens Agrud Partners
Advocatcs & Solicitors

Advocates & Solicitors
ll. Narinran Bhavan. T : +91 022 22810101
Nariman Point, !- : +91 022 22850104
Munlbai 400 021 Indra E ' mumbai@agntdpartnors com
www.agrudpartners com
No:278
APt2020
October 5, 2020 Bv Courier / Bv E-mail
Mr. Vikram Anand Singh

Proprietor, Being Creative
Bungalow 99. Aram Nagar - 2,
J. P. Road, Versova,
Andheri (West),
Mumbai - 400 061 E-mai I : vi ckv@be in sctre a tive. in
LEGAL NOTICE
^e:
Our Client: Mr. Mohommed Raza Surti, residing at Noor Manzil 3'd Floor, 72, Nizam Street,
Mumbai - 400 003
Sir,
Under instructions and on behalf of our Client above named. we write to out vou to notice as
under:
l. Our Client is a content producer by profession and holds a reputed name in the
advertising industry. Our Client is, inter alia, engaged in the business of procuring
advertising related projects and executing them to the satisfaction of his clients.
) Somewhere in the year 2018, our Client was introduced to you by a common friend.
Being impressed with our Client's expertise, knowledge and clientele base, you requested
our Client to join your proprietary concem 'Being Creative'.
3. Our Client was designated as Executive Producer in 'Being Creative'and the scope of
work of our Client was to use his connections and networking skills to procure
advertisement assignments from various corporate houses. It is pertinent to point out here
that you had always assured our Client that for all practical purposes, he was an equal
paftner in decision making and profit sharing in 'Being Creative'. You had further
represented to our Client that over and above the profit, our Client would be entitled to a
monthly compensation / salary ofRs.2,00,000/- (Rupees Two Lakhs only).
4. Since the business of 'Being Creotive' started picking up, there was need for more
creative manpower. Pursuant to mutual discussions, in 2019, one Ms. Aashita ('Aushita\
joined'Being Creative'as a writer. In the meantime in order to expand and take more
Aonuo PnRrxens
projects, with your consent, our Client started his own proprietary concem under the
name and style of 'ThingsVdo'
:1. Our Client states that for 2 years, you, Aashita and our Client worked extremely hard and
the business of both entities was doing very well. Our Client was able to procure
advertisement assignments from such corporate houses like Burger King, ECI, Flipkart,
Swiggy, Rupay, Uber amongst others.
6. Our Client states that once the nationwide lockdown was imposed on 24 March 2020,
business came to a standstill and no project was executed by either 'Being Creative' or
'ThingsVclo'.ln fact, there was no communication between you and our Client during this
period of inactivity.
7. Our Client states that on l0 September 2020, in a WhatsApp messenger group consisting,
inter alia, ofyou, Aashita and our Client, you accused our Client ofnot making payments
to vendors who had worked on various projects for 'Being Crealive'. To the utter shock
and surprise of our Client, allegations was made that our Client had applied for a tourist
visa to visit United Kingdom by impersonating as proprietor of 'Being Creative' and lhat
Aashita was mentioned as our Client's wife in the visa application documents.
8. Furthermore, you had shared an image of a letter dated 14 October 2019 purportedly
written to the Canadian High Commission by our Client as proprietor of 'Being Creative'.
The letter requests the Canadian High Commission to reconsider its decision to allegedly
deny our Client and his 'so-called' wife, tourist visa to Canada. Our Client states that he
had not applied for a Canadian Tourist Visa during the concemed period as our Client
already had a subsisting Canadian visa. Our Client states that the signature appearing on
the letter is not his and is clearly forged. Our Client has every reason to believe that the
said forgery is committed by you for the purpose of creating a false record.
9. With respect to alleged non-payment to vendors, our Client states that he had issued a
cheque for Rs. 12,00,000f (Rupees Twelve Lakhs only) in December 2019 from his
account in 'ThingsVdo' to clear the outstanding payments of the vendors. Our Client
states that the said cheque was duly deposited and encashed by you. Since the vendors'
dues have not been cleared, it is evident that you have misused and/or misappropriated
the funds. The allegationd made by you are onJy with the malafide intention to extort
monies from our Client and damaging our Client's reputation in the industry..
10. Our Client states that the manner in which Aashita's name has been dragged in the entire
conversation has affected our Client's mental peace and calm. Our Client states that he
had never imagined that.you would baselessly associate a colleague and friend's name in
such an inappropriate way. Our Client states that the allegations were not only bordering
on defamatory but also an attempt.to outrage Aashita's modesty together with maligning
our Client's reputation. The allegations have resulted in character assassination of both
Aashita and our Client.
Acnuo PlRrNens
It. tdespite assurances, our Client was shin in

an Executive Producer, our Client w ofRs.
however not a single penny has been g. you
months' salarv aggregating to
Rs. 46,00,000/- (*"o"ir"i#r"!;?:?i13',",1!*"*t-three)
12' Your conduct has not only caused financiar loss to our crient but
arso caused severe
reputational loss to our Client due to your unashamed and unreasonable
behaviour. In
view thereof' our crient is also-entitled to damages of Rs. 2,00,00,0001-
crores only) towards damages for loss of reputaiion and mental harassment inufees rwo
iaused by
your conduct.
13. In the aforesaid circumstances, we here

requisitions within l4 (fourteen) days fr
notice, failing which our Client will be c
against you at your entire risk as to the c
a) issue an unconditional apology to our Client;
b) give a written undertaking that you will not indurge in any

acts in the future that may
defame or cause humiliation to our Client in any manner wnatsoeveri
c) pay to our client or to us at his advocates, a sum of Rs. 46,00,000/- (Rupees

rorty
Six Lakhs only), towards salary for 23 months
@ Rs. 2,00,000.00 p", rnonih;
d) pay to our client or to us at his advocates, a sum ofRs. r2,00,000/-
(Rupees Twerve
Lakhs only), being the vendor payments advanced by our ilient
to yor;
'
e) pay to our Client or to us at his advocates, a sum ofRs.
2,00,00,000/_ (Rupees Two
Crores only) towards loss ofreputation, damage ancl mental harassment.
. .This Notice is being issued without prejudice to any other right that our client may have
under.law or in equity against you. our client arso rese.ves tris
iight to add, supprement or
amend his claims, as and when necessary and deemed appropriate
by him.
For, Agrud Partners


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Acnuo PlRrNens Agrud Partners

Advocatcs & Solicitors

October 5, 2020 Bv Courier / Bv E-mail

Mr. Vikram Anand Singh

It. tdespite assurances, our Client was shin in

13. In the aforesaid circumstances, we here

a) issue an unconditional apology to our Client;

b) give a written undertaking that you will not indurge in any

c) pay to our client or to us at his advocates, a sum of Rs. 46,00,000/- (Rupees

For, Agrud Partners

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