By Regd Post with Ack-due

Kadapa,
19-01-2018.
From:-
1. Sri.M.Ramanjaneya Reddy
Advocate
Door No:-2/468-1 Up stares,
Nagarajupet,
Kadapa city post and District
2. Sri.K.Venkata Reddy
Advocate
Door No:-2/476 Nagarajupet,
Kadapa city post and District
To:-
1. Sri.J.Pullaiah
Advocate
Door No:- 8/605, Prakash Nagar colony,
Kadapa city post and District
2. Sri.R.Chandra Obul Reddy
Advocate
Door No:-54/35, Sivalayam street Nabikota,
Kadapa city post and District

Sirs,
Sub:-Legal notice for taking legal steps by filing suit for damages for
writing defamatory pleadings made in O.S No:-43/2017 and in rejoinder
in O.S No:-43/2017 against us- Rg.
1. You No:-1 filed civil suit O.S No:-43/2017 and you No:2 filed
rejoinder against us in the Honourable Fourth Addl District Judge court at
Kadapa on Behalf of your client named Kumari M.Bhargavi By making
false and untrue allegations against us even though we wrote those
pleadings in T.O.P No:-339-2016 and in Counter in D.O.P No:-20/2016.
The rejoinder filed by you No:-2 in suit is totally with false allegations
causing damage to our reputation in the Bar of Kadapa as well as in other
Bars and also before the litigating public in general. The said allegations
are personally attacking our prestige and reputation before the Bar
association members of Kadapa Bar Association in particular and other
Bars in general. The Defendant No:-1 filed her written statement in
Telugu language wherein she categorically stated that the pleadings
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written by us are as per the instructions of the first defendant, in criminal
transfer application, counter in D.O.P No:-20/2016 and pleadings in T.O.P
No:-339/2016 basin on the pleadings in M.C No:-8/2013. Still you are
attacking us with ulterior motive even though the first defendant filed
her written statement categorically stating that we pleaded the above
pleadings basing on the pleadings in M.C No:-8/2013 on the file of
J.F.C.M court at Rajampeta which was prepared by advocate of the first
defendant named Sri.Nusruddin advocate of Rajampeta as per the
instructions of first defendant.
2.Why should you made such personal attack on us even though
we wrote such pleadings as pleaded in M.C No:-8/2013 on the file J.F.C.M
court at Rajampeta. You did not see and peruse the pleadings in M.C No:-
8/2013 but you are personally attacking us by pleadings that those
pleading are originated from us without the instructions of our client. You
did not make any allegations against the said advocate who prepaid
pleading in M.C No:-8/2013 on the file of J.F.C.M court Rajampeta as per
the instructions of the first defendant.
3.Now we are demanding you to state that who drafted the
pleading in the plaint in O.S No:-43/2017 and the pleadings in the
rejoinder. Please inform to us on that aspect who drafted the pleading in
O.S No:-43/2017 plaint as well as pleadings in rejoinder in O.S No:-
43/2017 in order to enable us to take civil and criminal steps against such
persons. The pleadings made in the rejoinder are dangerous and
unethical to the legal profession and making large amount of damage to
our reputation. We are senior advocates having good reputation in
Kadapa Bar Association as well as in other Bars in Kadapa District.
4.Therefore please take this legal notice and that you are
requrested to state that who drafted the pleadings in O.S No:-43/2017
suit plaint as well as in rejoinder in O.S No:-43/2017 in order to enable us
to take appropriate legal steps against such persons both in the court of
law as well as before police by holding them liable for costs and
consequences.

Advocates