rgz}andaftani ~rWciatej.

ADVOCATES 'THRUPTHI', T, D. ROAD NORTH END, COCHIN-682 Phone: 2368585, 2362025, Fax: 0484-2360913 e-mail: kpdandapani@hotmail.com 035

Speed Post with AID

14.02.2012

To Shri Kirit Sornaiya, 91C. Neelam Nagar, Mulund (East), Mumbai, Maharashtra - 400 081 Email: kirit@vsnl.in:kiritsomaiya@qmail.com:ksoffice@rediffmail.com: Qjpupmediacell@gmail.com; webmaster@bjp.org:

1. We are under

instructions

from

our client

MIs. Ziqitza

Health

Care

Limited, 401 B, Niranjan, following

99 Marine Drive, Mumbai 400 002 compliance

to send the

notice to you for immediate

2. Our client, Ziqitza the Indian Ziqitza Companies

Health Care Limited Act, 1956. Ziqitza

is a company Health Care

incorporated Limited

under

is part of

Group

founded

in 2002 to establish, (Life Support

propagate

and popularize Service) in India

emergency

medical

service

Ambulance

which can save lives in a medical emergency. started the initiative for the Life Support

The promoters Ambulance

of our client as an

Service

organized

Emergency

Medical Service in Mumbai in 2002 at a time when run Emergency Medical Service after Ambulance

India did not have any professionally they realized the acute

need for organized

and networked

service in India

rpj}andajtan/

~:J,O-Ctate:J,

ADVOCATES 'THRUPTHI', T. D. ROAD NORTH END, COCHIN-682 035 Phone : 23~8585, 2362025, Fax 0484-2360913 a-marl: kpdandapani@hotmail.com

3. Our client's founders April

started the initiative with 1 Ambulance 'Dial

in Mumbai with

in

2003 and launched
life Support

1298 for Ambulance'
on

in Mumbai

10

Advanced

Ambulances

21 May, 2005 The initial capital of
family and friends

Rs. 2.00 crores

was brought

in by the five promoters,

over a period of 4 years starting rounds of funding from globally

in 2002 till 2006. Our client also raised two reputed investors in 2007 and in 2010 to

scale up the operations

4. Our client has over the 9 years since incorporation leading Service) company in India in Emergency providing Life Medical Support Bihar Service

grown to become

the

(Life Support Service running

Ambulance in Kerala,

Ambulance and Punjab,

Maharashtra Ambulances

(Mumbai), at present

Rajasthan,

825 plus

5. Our client operates
Ambulance through Service with

"Dial model) the

108 in Emergency"
in public various private

(popularly partnership

called the contracts

108
won

tenders

State

Governments

for the service

respective is offered

State Government

/ NRHM program.

The 108 Ambulance

either free to patient or on a user fee as per the contract State Government. medical by
OUf

with the respective J victims in

The service

is usually women.

provided

to patients

emergencies

and pregnant

The details

of the tenders

won

client are provided

herein below:

I
151. No

I

I

t--1

rear

istate

007

F'h;-

__

1Ruling party .in the Istate at the time of _Je~e_r_ !JDU & BJP

INo. of A bI I_:~nce
1

I

10 Nos

J

I

PlJandajtani

~:fo-ciate:f

ADVOCATES 'THRUPTH!', T. D. ROAD NORTH END, CDCHIN-682 035. Phone: 2368585, 2362025, Fax: 0484-2360913 e-mail: kpdandapani@hotmail.com

2
3

2008 12009 2009

Kerala Bihar Rajasthan

CPI(M) led LDF DU & BJP INC rkali ISJD Dal & BJP

37 Nos 37 Nos

15
1

r-6

r

r64 Nos 240 Nos 280 Nos.

12010 Punjab 2011
Odisha (Under implementation)

6. Our client Governments below: SI No ear

has also lost out in several

tenders

floated

by various

State

over the course of time as per the details provided herein

State

ender for Operation of Mobile Medical Units Operation of Health Helpline ePeration of Ambulances

Ruling party of the state at time of tender

1

2010-2011 2010-2011 2008 011

Rajasthan Rajasthan Delhi Maharashtra Himachal Pradesh

r-2

IINC IINC INC INC

_
3

I-5 2010 2010

Operation of Health Helpline

_---

f-BJP BSP

Operation of Ambulances

~

Uttar Pradesh Ope~ation of Mobile IMedlcal Units

7, Our client brings organization Emergency commercial in

to 108 Ambulance to have the

Service experience

its experience of running (EMR) Bihar,

as the only an in effective India's

India

Medical capital

Response and largest

Ambulance city Mumbai,

Service Kerala,

Rajasthan,

rgz}andaftani

4

~",o-ciatej,

ADVOCATES 'THRUPTHI', T. O. ROAD NORTH END, COCHIN-682 035 Phone: 2368585, 2362025, Fax 0484-2360913 e-mail: kpdandapani@hotmail.com

Punjab (10.00 calendar

and soon in Odisha. Lacs) plus individuals

Our client has transported faced with medical

over 1.0 Million in the

emergencies

year 2011 alone

8. Our client's Ambulance Mumbai during

service

has provided

valiant

EMR coverage

to

major disasters

(natural service

and man-made) in Mumbai

and round the

clock on normal days. Our client's 7/11 serial train blasts, 26/11

during the unfortunate

Mumbai Terror attacks and the recent serial and appreciation from all

blasts have been a matter of record, recognition sections of the society.

9. Mr. Ravi Krishna, funding second

holds 1.25% equity of the company wife holds 2,68% equity

post second

round post

and Me. Krishna's round funding.

of the company

10. Mr. Karti P. Chidambaram Neither

is an Independent

Director

of the company. hold any shares

he nor any of his family members

or his associates

and / or beneficial

interest in any form whatsoever

in the company.

11 Our client has won several accolades 'Special Recognition'

including

the following during 26/11'

for the outstanding

work in Mumbai

by BCI and Deloitte 'Continuity & Recovery Initiative of the Year in Public by BCI and Deloitte Shakti Award_to Ms. Interest' award

for the 1298 First Responder Tata Group and TiE conferred

Program

the Tata TiE Stree

Sweta Mangal for leading Dial 1298 for Ambulance

PlJandafani

~:H),ciatej,

ADVOCATES 'THRUPTHI', T. D. ROAD NORTH END, COCHIN-682 035 Phone 2368585, 2362025, Fax 0484-2360913 e-mail kpdandapani@hotmail.com

Godfrey Godfrey

Philips Bravery Philips Bravery Region,

Award for Social Act of Courage Award India) (Gold) for the Social

2007

Act of Courage

2007 (Western

Times Foundation Project and Harvard Oxford

Recognition

Award for Life Saving Service

'06

1 or Case Study at:
Business University Business School Said School School

Columbia University Selected (1

of Michigan for the prestigious Global Social Benefit Projects Incubator Program

to 20 Social Entrepreneurship

from around the World)

12. Our client has a sterling

reputation

in India and internationally.

From the in the

above, it is clear that our client is having very high status and goodwill society and excellent relationship within the social, academic,

business,

government

and political circles in India and abroad.

13. With the sale intention referred and you

of defaming

the reputation

of our client, you have

to our client in your statement have intentionally illegitimately While the made

given to the rnedia dated 06102/2012 various allegations about our client

winning and

contracts

in Congress allegations

party ruled states like Rajasthan made by you against the

Maharashtra.

Government officials falsely

of Rajasthan,

Government

of Maharashtra,

NRHM"

various

and Congress alleged

party are not of direct concern

to our client, you have of

defamatory

matter about our client with the sole intention

rpj)a-ndafta-ni' ~:wc';ate:J
ADVOCATES 'THRUPTHI', T. D. ROAD NORTH END, COCHIN-682 035 Phone: 2368585, 2362025, Fax 0484-2360913 e-mail kpdandapani@hotmail.com

defaming defamatory

our client, tarnishing allegations on made

their image and sullying by you against our

their reputation. client in your

The press

conference issued media caused Your

6th February, 2012 in Lucknow and the Press Release
of Bharatiya your website Janata Party (BJP) to the have and through www.kiritsomaiya.com to our client's in Dainik dated

by you on the letterhead in Lucknow grave,

serious

and irrepairable have 2012, since

damage printed

reputation. (Delhi

defamatory dated
7th

statements February,

been

Jagran
7th

Edition)

Dhainik

Bhasker

February, and 2012, by on

2012, www.upnewslive.com Website

7'h

February, since

2012 and TV Channel February,

www.zeenews.com

www.moneycontrol.com PTI causing multiple countries

since yth February. statement world

2012 and widely our clients in UK,

circulated to appear and

your defamatory around including the

against

websites in Europe

especially

USA

other

http://specialsJorbes.com

14. With the sale intention referred and you Ambulance charges to our client have falsely

of defaming

the reputation given

of our client, you have dated 06102/2012 of the 108

in your statement alleged

to media

that the contract of Rajasthan

for operation

service

in the state

run by our client

is facing

of corruption.

15.

Our client would like to inform you that the contract Service in Rajasthan

for operation

of 108

Ambulance tender bidders, Further,

was won by our client through

a transparent

process our

in 2009 in which four parties had participated. client was informs the lowest bidder

Out of these four per month in the

(L 1) at. Rs. 94,899/price vis-a-vis

our client

that our client's

other bidders

Pl5anclafani

Q!)</;,'H),oiate:J

ADVOCATES 'THRUPTHI', T. D. ROAD NORTH END, COCHIN-682 035. Phone: 2368585, 2362025, Fax 0484-2360913 e-mail: kpdandapani@hotmail.com

tender

had saving to Govt of Rajasthan

(NRHM

Rajasthan)

of a minimum

of

Rs. 76.66 cores and Rs. 153.75 crores respectively L2 and L3 bidders in the contract. Ambulance Ambulance the contract service in Rajasthan

from the prices quoted by 108 108

Our client also takes pride in providing at the Lowest Contracted Price for

Service in any State in India by any organization price of Rs.

through tender at

94,899/- per month per Ambulance
into any arrangement and /

16. Our client confirms

that they have never entered or Government

or contract with any Government transparent respective

agency except through a

bidding process wherein our client was the lowest bidder in the tender. Further, our client has publicly taken position that they which uses public funds other

shall not enter into any contract or agreement than through a transparent

bidding process wherein our client is the lowest

bidder. Further, our client has won 8 out of the 12 tenders for running the

108 Ambulance

Service

in various

States

in India which

resulted

in 6

separate contracts with 5 State Governments

17.0ur

client wishes to place on record that our client is a professionally built over through the last 9 years. Our client serves various

run State

company

Governments

contracts

won through

public tenders.

Incidentally, in

our client has secured

five out of 6 contracts

with State Governments

states ruled by non Congress and award of contract

party Governments

at the time of tendering in states ruled by

and has lost 4 out of 6 tenders as laid out in paragraphs

Congress party Governments 18. The statements
OUf

5 & 6.

made by you and as published

by the media referring to to our client. The

client and our client's directors

are per se defamatory

rgz}andafani

s

~j,(i-oiateJ,

ADVOCATES 'THRUPTHI', T. D. ROAD NORTH END, COCH1N-682 035. Phone: 2368585, 2362025, Fax 0484-2360913 e-mail: kpdandapani@hotmail.com

printing,

publication allegations

and

circulation

of your

statements

containing

the

defamatory enquiry

as above by you is without any document

conducting

any proper enquiry was

or without

verifying

If a proper

conducted

and a proper verification statements

of the documents

had been done, the

above defamatory

about our client would not have been made statements contained in your statement accusing our client

by you. The above

defamatory

given to the media and as published with the allegations the eyes defamatory defaming health aforesaid lowered

in the media falsely

the status and dignity and well wishers.

of our client in The above of the

of the general statements the status

public, were

associates

published

by you with the sole intention in general abroad. and within The

of our client community

in the Society in India and

and

medical as stated

defamatory has caused status in the the future and

statements

by YOLi and as published

by the media

very great damage society, prospects business well

to our client in as much as the company's and relatives have been lowered

wishers

and

of our client fields

in the social,

political, seriously

academic, by such

professional

have been affected statements the

publication.

Further, attempt on

the defamatory your

as above is a deliberate Image of our client

and criminal

part to tarnish goodwill and the

and destroy

the company's community no verification
III

reputation, particular whatsoever client's

and standing society

in the health and medical Further, there was

at large.

with

our client

and I or our client's specific

promoters

and J or our in

management

even though

allegations

have been made

the letter

PlJandajtani

~iJo-ciateiJ

ADVOCATES 'THRUPTHt', T. D. ROAD NORTH END, COCHIN-682 035. Phone: 2368585, 2362025, Fax: 0484-2360913 e-mail kpdandapani@hotmail.com

19.0ur

client instructs

that you connived, as cited

conspired

and deliberately

made the intention to and

statements defame business without inimically nefarious

to the media

above

with the calculated career prospects

our client fields.

and scuttle

our client's

in social

Our client further any proper

states that the said statement enquiry whatsoever at the

was made instance of

conducting disposed purposes.

socio-political

and business

rivals

of our client for

20.ln

the

above

circumstances, apology

our

client

demands

publication in which

of

an your and

unconditional statements imputational letter printed, Lucknow

in all the newspapers at a prominent statements

and websites

was printed defamatory published dated

place stating

that the implied

about our client published by you in the press posted in Dainik dated 2012 in Jagran 71h

in the signed conference in

and circulated and

0610212012 which 2012, since

your (Delhi February, TV

website Edition) 2012, and 2012, by on

www.kiritsomaiya.com dated 71h February,

was carried Dhainik

Bhasker

www.upnewslive.com Website

th th

Febr~ary, since February,

and

Channel

www.zeenews.com since

February, 2012 and widely our clients in UK,

www.l1loneycontrol.com PTI causing multiple countries

circulated to appear and

your defamatory around the

statement world

against

websites in

especially

USA are

other

Europe

including

b..t.1J2.JLspecials.forbes.com

absolutely

found to be untrue within seven days of receipt of this letter and further that you pay a sum of Rs. 2.50 crores within a period of 14 days as and

compensation mental stress

for the defamation that the

and all consequent management

damages, and staff

trauma

promoters,

of our client

rpj}andajtani

I

~:Jo-{}iate:J

ADVOCATES 'THRUPTHI', T. D. ROAD NORTH END, COCHIN-682 035 Phone: 2368585, 2362025, Fax: 0484-2360913 e-mail: kpdandapani@hotmail.com

suffered remedies

failing which against

our client will be constrained

to initiate

any / all or

you available

to me in Law, whether

civil, criminal

otherwise and in such event you will be held personally consequences, direct, indirect, damages that have occurred consequential,

liable for all costs,

to me or occur to me, whether compensatory or punitive for

incidental,

which you alone are responsible

and liable to all costs and consequences

thereof to our client which you may please note.

Yours faithfully

Pl5andaftani

I~j,ociate:J

ADVOCATES 'THRUPTH1', T. D. ROAD NORTH END, COCHIN-682 035. Phone: 2368585, 2362025, Fax 0484-2360913 e-mail: kpdandapani@hotmail.com

Enclosures Copies of Reports as appeared 1. Download in News Papers and Websites. by Mr Kirit

of Press Release on BJP Letterhead BJP

Sormva, Secretary, www.zeenews.com 3. PTI Dainik Jagran 5. 6. 7. 8.

(Delhi Edition) (Jaipur Edition)

Dhairuk Bhasker

www.upnewsJive.com http://speclalsforbes.com www.moneycontrol.com BJP Media Cell

10

Oigambar Singh Article in Oainik Bhasker

Jaipur

Copy to

PTI ZEE NEWS UPNEWSLlVE.COM DAINIK JAGRAN DAINIK FORBES OUTLOOK Shn 0 INDIA P Kohli. BJP Headquarters In charge. Email: BHAKSER

opkohl11935@gmail.com Shri. Digambar Singh, MLA, Rajasthan State Assembly

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