THROUGH REGD.

AD POST/ COURIER

Dated: ______
To,
Golam Mostafa

Sub: Reply to your Legal Notice dated 27.09.2018 issued on behalf of your client
Golam Mostafa, M/s Alif Casual Wear Ltd. Having its Corporate Office at Bilkis
Tower (9th floor) House No. 06, Road No. 46 Gulshan-2 Dhaka-1212.

Dear Sir,

We have been handed over your legal notice dated 27th of September 2018, which
was issued from your good office to our client namely Bapon Kumar Roy, Head of
Customer Relation Management, Freight Options Ltd. having its registered office at
206/A Level # 3, Tejgaon Industrial Area, Dhaka- 1208.

PRELIMINARY SUBMISSIONS/OBJECTIONS:

1. At the outset, we have instructions to state that your client has not apprised
you the correct facts which resulted into issuance of this frivolous notice. It
appears that your client has misrepresented the true facts deliberately and has
concealed its misdeeds and wrongs done against our client. It is further stated
that averments made against our client in the subject notice are wrong,
frivolous and misconceived, hence they are denied.

2. That the true facts pertaining to the present matter may be noted. Your client
M/s Alif Casual Wear Ltd along with its group/channel Company M/s Alif
Industries Ltd. approached our client and represented to shipment of
 mentioned goods Los Angeles via Colombo by Sea/Air and Air on dated
………………………………….. . Our client being reputed freight forwarder accepted
to shipment of our Client.

3. That your client was further induced our client and its group Company for
providing loan facility from our client for mentioned shipment. Though the
payment mode of freight is prepaid. Our client agreed to give your client 50%
percent loan.

4. That our client with good faith and for interest of the business had taken step
to shipment of the goods of your client being freight No. SA-I - 180700015
HAWB FOLSA18070020; SA-I- 180700014 HAWB FOLSA18070018; SA-I -
180700010 HAWB FOLSA18070011; SA-I- 180700011 HAWB
FOLSA18070010 and two Air Freight Folso-180755098 HAWB FOLA1870078,
18075099 HAWB FOLA18070079.

5. That your client was not responsible enough to make payment of the dues
against the above mentioned carriage.
6. That our client had sent several email for payment and finally sent an email
dated August 01, 2018 to your client, wherein our client had mentioned that
your client had been crossed credit limit. Our client also requested to your
client to pay by Cash/PO BDT 20,00,000.00 (twenty lacs) by that day from total
dues of BTD 40,22,544.15 ( forty lacs twenty two thousand five hundred forty
four point fifteen).
7. That our client notified your client the reason of cancellation of two shipments
on august 01, 2018 and liabilities were totally upon your client for non-
payment of dues. So you are wrongfully mislead and misguided by your client
with malafide intention regarding invoice no. ACWL/EXP/2018/013 and
 invoice no. ACWL/EXP/2018/014. Of two Air Freight Folso-180755098 HAWB
FOLA1870078, and 18075099 HAWB FOLA18070079.
8. That you are also wrongfully mislead and misguided by your client with
malafide intention regarding invoice no. ACWL/EXP/2018/050 and invoice no.
ACWL/EXP/2018/053. Which were forwarded to the destination as per
Schedule on Arrived lax July 31, 2018 Delivery Taken August 01, 2018 and
Arrived LAX- July, 31 2018 and Delivery Taken August 01, 2018 respectively.
SA-I - 180700010 HAWB FOLSA18070011 MAWB 0162270286 and SA-I -
180700015 HAWB FOLSA18070020 MAWB 01622702290.

9. That you are not fully informed and your client misused your good faith
regarding invoice no. ACWL/EXP/2018/052, SA-I- 180700014 HAWB
FOLSA18070018 MAWB 01622702216; and invoice no. ACWL/EXP/2018/049,
SA-I- 180700011 HAWB FOLSA18070010 MAWB 01622702275 which were
delayed due to natural calamities and that matter was discussed with your
client through U.S.A. agent of your Client Mr. Usman on dated through Whatsup
Communication on dated on. …………………..
10. That your client has not made full payment of the mentioned invoices, though
the invoices are made on July. Your client is categorically delaying the payment
and instead of the payment send this notice. Which indicate ill motive of your
client and mislead you to send such kind legal notice.

11. That from the malafide and arbitrary acts on part of your client along with its
channel partner compelled to our client to take legal action to recover the
financial loses.
12. Vide this notice, it was also stated that your client is liable to make all payment
to our client and your client has been clearly advised to settle the accounts with
our client Company against the invoices made by our client company.
13. Thus it is obvious that the notice in question have been send with malafide
intention and with an oblique motive to harass and blackmail to extort a huge
sum of money from our client.

At the outset, it is pertinent to mention here that your client has concealed the
material facts from you thus, has misused your good office for getting this false and
frivolous notice issued against our client. Moreover, our client also, at the outset,
denies each and every averment made by your client in the notice under reply save
and except what has been specifically admitted herein below.

CATEGORICALLY REPLY:

1. That the contents of lines No. 1 of the notice under reply are denied to fully
that existence of such kind agreement is totally false and frivolous.
2. In reply to lines no. 2 and 03 of the notice, it is stated that our client agreed to
shipment of goods but our client has not any failure and non-compliance of
our client. The contents of preliminary submissions and objections may also
be read as part of reply to these lines also.

3. That the contents of table on second page of the subject notice are wrong and
incorrect, therefore, are emphatically denied. The presentation of these
information by your client is denied for want of knowledge, misleading.
However, your client was clearly informed by our client about the
cancellation of air freight and also informed the reason of delay to you agent.
The contents of preliminary submissions and objections may also be read as
part of reply to this para also.

4. That the contents as stated in corresponding paras of the subject notice are
wrong and incorrect, therefore, are denied.
 In reply to last para of the notice, it is stated that our client has no liability to
pay any amount and the subject notice and claim made therein against our
client is fictitious and frivolous. It is further stated that any legal or other
action initiated against our client by your client shall entirely at your client’s
risk, cost and consequences and our client reserves every right to initiate
legal action for damages or other remedies from your client before
appropriate Forum/s, which kindly note.

Therefore, you are requested to call upon your client to withdraw the above legal
notice against our client henceforth, falling which our client will be constrained to
initiate the appropriate legal proceeding and also defend if need arises at the cost
and consequences of your client.

Copy of this reply has been retained in our office for future action and references.

For
Singh & Associates

Advocate