DATED: -19.08.

2020

LEGAL NOTICE
SPEED POST/REGD. AD.

TO,
1. NAMAN GUPTA
2. VOLTED PC

COMMONLY AT:-
NEHRU PLACE-303, 3RD FLOOR ,
DOHIL CHAMBERS,
46 BEHIND SATYAM CINEMA,
NEHRU PLACE, NEW DELHI
Mail id :-contactus@voltedpc.com
+91-9999931521

Sir,

On behalf of my client, Advocate Jaikush Hoon founder & Managing Partner

Demeterali Legal C-511, CR Park, New Delhi-110019, I have been instructed to
serve you with the following legal notice:-

1. My client Advocate Jaikush Hoon is a well reputed Lawyer in legal

fraternity of New Delhi & around. The people who knows him they know it
that he is diligent, hard-working individual. His image in legal profession
has been spotless since the inception. Whereas my client has come across
a comment which was shared to him by one of his known person. The
 same was posted online/search portal by you the noticee no.1 at the
comment section at his firms page in google search a month ago ie
September,2020. The same has been reiterated here as:-

“Horrible team they have, complete waste of money and time. In April of
2019 I visited Advocate Jaikush in his south Delhi office. He took my case
discussed always in a hurry pretending or maybe actually a very busy
person, either way if you make an appointment treat the person you are
meeting with some diligence. They filed my case after roughly 45 days,
promised to me was 15. The team is/was (they switched their staff every
week). Silly mistakes is something which is common for them but it costs
thier clients another date in the court causing loss to their business. They
couldn't file the tracking of the summons properly and it has been 1 year
since. The date gets delayed everytime. To top it all off the advocate
promises that he personally will represent you in the court but he never
did. His young and incompetent team of advocates will represent you. The
defendant in my case failed to reply to our summons in the given time
period, against which the judge ordered a fine of ₹3,000/- my lawyer was
so naive and amature that he didn't take it in writing and in the next date
we were back to square one. A lawyer should make your legal fight easy
for you, constantly called them for updates and dates but they never
cared to reply. Finally when I did decide to change lawyers advocate
Jaikush did not even hesitate and asked to pickup the files. Worst of all,
when I sent my staff to pickup after several notices in text and calls (I
tried but they didn't pickup) they gave only half the files back. On asking
around his rude behaviour was back in action. If you have a small case in
which this lawyer is not making much never consult or hire him, to him
you are just another dumb client who can be fooled for his/her money and
he thinks all the small cases his juniors can handle who change every
week or so. Never the same lawyer represented me, everytime a new one.
Unhappy..”

2. That to start with, I would like to address the conjecture & image projected
by you the noticee no.1 against my client & his office is completely
baseless, concocted and untrue. You the Noticee no.2 was my client’s
client till second quarter of August,2020. In August,2020 your complete
file/files were handed over to your staff person ie Sonu who visited by
client’s office dated:-27/08/2020. My client’s holds a written receiving
from your staff where it is clearly mentioned that you have received the
complete set of files from my client’s office. The same receiving would be
produced at appropriate time before requisite place if so required. My
client also retains a video where your staff person had received the files to
his optimum satisfaction from my client’s office. So you the noticee no.1
 must realize by now that the said allegation of yours is completely absurd
and baseless.
3. That you the noticee no.1 twisting the whole situation to blame my client
& tarnish his & firm’s image in the fraternity and otherwise. Now your said
allegation turned out to be completely false and utterly baseless. Your
false & baseless allegations are direct imputation against my client to
intend harm to his reputation & firm. Your imputation is directly in the
estimation of others to lower the moral or intellectual character of my
client. Also your imputation is directly in the estimation of others to lower
the credit of my client to believe that is in a loathsome state & in a state
generally considered as disgraceful.

4. That now coming to the second accusation made & mentioned by you the
noticee no.1 in the same post regarding monitory aspect where you
categorically mentioned that that it was a complete waste of time and
money. I would like to firmly respond to you the noticee no.1 on that there
was not a single money transaction made on your behalf which was
received by my client & his office or there was no cash transaction between
you the noticees and my client. The matter was referred by an online
portal and my client took care of your legal interest in the best of his
capacity even after the same portal collapsed. My client never demanded a
single penny from you the noticees for the any kind of proceeding in the
case. Infact for the PFs & court process ,my client paid the amount from
his own pocket & never demanded the remuneration from you the
noticees.

5. That your case was taken up by my client’s firm in the 2 nd quarter of 2019.
Right after the first conference, you were advised to supply requisite
documents pertaining to your case. Where you the noticee no.1 failed to
supply the documents to my client’s office on time. After receiving those
documents a legal notice was prepared & the same was sent to the
defendants where 15 days time was given to the defendants to respond.
The said legal notice was shared with you the noticee no.1 before sending
it to the defendants. So no promise was ever made to you on behalf of my
client’s office for filling the said suit in 15 days especially when we have
given 15 days’ time to defendants for responding. So you the noticee no.1
had failed again to establish your allegation against my client & his office.

6. That later the suit for recovery was filled before the saket court, New Delhi.
As the defendants of the suit were from out station, hence the service to
 them apparently was tedious process which exhibits your unclear
understanding towards court procedure. The summons were issued
onbehalf of the Hon’ble court against the defendants to appear before the
court but the same could not be delivered as they refused to receive them.
The same process has nothing to do with my client & his office. It seems
difficult for your little brain to fathom correctly that the that the court’s in
usual process do not pass an ex-parte decree on the first or second date in
any case. The defendants are always provided sufficient opportunity as
well thought/decided by Hon’ble courts. In your case the judgment
summon were prepared and was fixed for PF of the same in the month of
February 2020. The PF for the same was also filled on your behalf by my
client & his office.

7. That later it is not a hidden fact from anyone that the world was hit by a
pandemic followed with lockdown and so on. But you the noticee no.1 as
an impatient individual who have no reasonable understanding of court
pleading and procedure kept on asking about the court proceeding even
during the lockdown times. On Contrary my client office was more than
Cooperative to share all details pertaining to the matter. When this was
not to appreciable to you , my client told you to contact him directly if you
the noticee no.1 come across any confusion pertaining to your case. But
you the noticee no.1 instead of appreciating my client’s gesture you made
a malicious comment on public forum against him & his firm and the
same is visible to all now. I profusely make a statement that this was done
by you the noticee no.1 to purposely defame my client and his office for no
sensible/reasonable reason provided or exhibited from your end. Probably
you had some insane imagination to settle your score against my client
and you the noticee no.1 thought of it as the best way to go ahead against
him & his office.

8. That you the noticee no.1 instead of giving little encouragement to the
brain of yours or little time to your conscious to realise the correct
professionalism exhibited to you the noticees by my client & his office, You
the noticee no.1 choose to malice my client’s & his office reputation. As
you the noticee no.1 is well aware that not a single date went unattended
onbehalf of my client’s office still you the noticee no.1 did not fail to blame
my client & his office in public. Even in the lockdown & after, you the
noticee no.1 was updated about the dates in your case as like any other
client of my client’s office.
9. That you the noticee no.1 in the month of June,2020 expressed his
willingness to have a talk regarding an advisory pertaining to your case.
Inspite of the lockdown my client didn’t hesitate once and politely agreed
to have a word with you the noticee no.1. I would like to say that my client
hold the recording of you the noticee no.1 expressing to settle the matter
with the defendants and later the same followed with a phone call between
you the noticee no.1 and my client. After hearing the said recording my
client called you the noticee no.1 himself to guide you through the
situation (recording for the same is also available).

10. Later you the noticee no.1 did not apprise my client or his office about that
situation. Until august,2020 where you the Noticee no.1 made your
brother call my client who has no business to call him at the first place as
he is/was not acquainted with him through you or otherwise, that was the
first time that my client had a word with him. He straight way got to the
impolite tone & bad verbiage asking about the status of NCLT pertaining to
your case. My client had no recollection about the said status as there was
no conversation took place between him and you the noticee no.1
regarding the NCLT issue except that the same option could be browsed
was discussed. The same day my client made it clear to your brother that
he could take away the files from the office and has not spoken to you the
noticee no.1 since then.

11. That it is shocking that such post was written by you the noticee no.1
against my client after you receive the complete set of files and no money
was ever demanded from you the noticees by my client for all the dates he
appeared in your matter, all the drafting he has done in your case even
after the said subscription expired. My client & his office did not make you
the noticees suffer in any professional manner/situation rather he tried to
empathise with your immaturity by letting you pick up the files without
any payments to be made or hassle to be created. On contrary you the
noticee no.1 have defamed my client & his office on public platform by
sharing false and concocted story to damage the reputation of my client &
his office. It is Needless to say that it was wilful attempt and well-thought
out plan of yours to undermine my client’s reputation in public to carry
out your personal vendetta against my client & his firm. In spite of any
payment made to my client on your behalf , my client didn’t leave the case
in perils rather took care of the matter properly and returned the files to
your staff member without demanding any payment.
12. It is a epoch-making to mention here that My client & his office spent more
than sufficient time and energy which is clearly invisible to you the noticee
no.1 as clearly you intentionally refrain yourself to see anything positive
around yourself. My client has sufficient facts of the case, recording ,
texts, messages to prove that it was rather your conduct which is in
question throughout and all your allegations are completely baseless and
false. My client & his office was never there in the picture to make you
happy they were there to take care of your legal interest before the courts
which has been kept intact till my client left your case in August,2020.
My client’s team did sensible coordination to keep your matter intact
whether it is PF, Applications or any other requisite compliance as ordered
by the Hon’ble court but unfortunate that you could not see their efforts
and intentions from the correct prism. I believe that your ugly insecurities
have come out in open at the wrong time, for the wrong reason against the
wrong person ie my client.

13. That no promises was ever made onbehalf of my client to appear in your
matter on every date . Rather it is always the requirement/stage of the
case where my client or any senior counsel shall appear in matters.
Clearly there was no such occasion in your case before the court to do so
as the pleadings were getting completed. There is not a single text where
you the noticee no.1 have expressed your dissatisfaction to my client till
the time my client was looking after your case. It was only after when my
client had returned your files and withdrew his legal representation from
your case that you made such demining allegations against him & his
office. Perhaps it was your ego which got hurt when my client asked you to
take back the files as you were purportedly unhappy with him.

14. That the intentional vilification made by you the noticee no.1 in the said
post seems like it’s direct message/suggestion to others that they should
not approach my client or his office for legal services for several unfair &
false reasoning shown by you the noticee. People like you the noticee no.1
deserve a lesson to be taught in life, They must understand that if you the
noticee no.1 can’t appreciate someone’s kindness then they also shouldn’t
be disgraceful like this as you have been to my client in public. My client
take all your allegations seriously as they all have been made by you the
noticee no.1 with an acute malice and straight propensity to defame my
client & his office.
15. That I am feeling little astonished to explain to you the noticee no.1 that a
lawyer have no jurisdiction in the court orders made by any Hon’ble court.
A lawyer in its professional capacity could make a submission before the
court and leave it to the court to decide its fate. A lawyer cannot dictate
the court rather can always submit before the court. But clearly you the
noticee failed again to understand this simple fact about the court
procedure or common ethics.

16. It is utterly shocking that in spite of providing the regular updates

pertaining to your matter you the notice no.1 has an audacity to say that
it was you who was following with my client’s office. You the noticee no.1
should be self-ashamed of your behaviour and conduct exhibited against
my client & his office in public.

17. That coming back to the allegation where my client did not refuse to
return the files rather permitted to you the noticee no.1 to pick up your
files and suggested to choose yourself another legal representation. The
same seems to be more than fair to many reasonable minds unlike yours
as there was no money was demanded and your files were returned hassle
free. Your staff boy who came to my client’s office to receive the complete
file and gave a noting of receiving the complete files. I believe the same was
not shared to you the noticee no.1 by your staff otherwise you the noticee
no.1 would not have made such serious allegations against my client. It
absolutely rubbish of you the noticee no.1 that any of my client’s office
staff spoke to you rudely, there was not a single person who spoke to you
the noticees in that manner. The files were kept out to be picked up the
same moment when you the noticee no.1 was informed to pick up the files
from my client’s office. If my client have had any vested reason to do what
all you have alleged then my client would not have offered you to pick up
the files from the office or he would have demanded the payment first for
the dates his office had appeared in your case before the concerned court.

18. Your online post just not depict your experiences about your case with my
client rather it is an ill advice which was made public against my client &
his office for the facts which are totally twisted and compromised by you
the noticee no.1 for your own suitability & taste. You the noticee no.1 has
no business to comment on my client or his office at all in public
especially when they have done no harm/wrong to you the noticees. You
 the noticee No.1 purposely trying to malign my clients reputation in public
probably because you could not be kept happy. let me tell you with your
bamboozled Wisdom and scratchy understanding of simple facts, It will
always be you who would be responsible for your own unhappiness not
others or my client.

19. Moreover from the sequence of events detailed herein above, it is clear that
the attitude, conduct and behavior of you the noticees is reckless and
irresponsible and further by not appreciating the gesture of my client &
his office. I feel no doubt in saying that you the noticee no.1 is an
individual who feel no shame in maligning anyone’s reputation inpite of
the fact that the said individual has rendered all cooperation & harmony
in the best of his capacity.

20. That the attitude, conduct and behavior of you noticees is deplorable,
careless and is nothing short of deficiency of professional & moral
responsibilities apart from damaging my client’s reputation which is
directly subjected to his mental peace and defaming its name and
reputation, as such  we are  left with no other alternative, my client are
constrained to get issued this legal notice to you the noticees.

I hereby call upon you noticees, jointly and severally to Remove the same
post from the said comment section where you the noticee no.1 have
posted with immediate effect and render a public written apology to my
client & his office for the misconduct exhibited on your behalf against my
client & his office and pay to my client the compensation amount of
Rs.10,00,000/- for the mental agony and trauma caused to my client for
tarnishing his image and his office’s reputation in public. Besides Rs.
50,000/- as our professional fee towards issuance of this notice within 7
days from the date of receipt of this notice, failing which I have definite
instructions to initiate appropriate proceedings (both in civil as well
criminal courts and other forums) against you in the competent courts
of law entirely at your risk, costs and responsibility. against you in the
competent courts of law entirely at your risk, costs and responsibility.

Yours faithfully,

REGARDS
 ADVOCATE

P.S-Copy of the legal notice is retained in my office under the instructions of

my client to take appropriate action