KALPESH JOSHI ASSOCIATES Advocates By Regd. AD/ Email 22 March 2019 To, Mr. Aamir Khan, Advocate. A-250, Ground Floor, Defence Colony, New Delhi - 110 020. Sir, Re: 1. Your Demand Notice dated 26 February 2019 received by Juniper Hotels Pvt. Ltd on behalf of your client Jitter represented by LIMN ENT. LLP. 2. Our clients email dated 4 March 2019 to Mrs. Divya Samdhani. 3. Your withdrawal email dated 7 March 2019 addressed to representatives Of Juniper Hotels Pvt. Ltd, We are concerned for our clients Juniper Hotels Pvt. Ltd, having their address at Off Western Express Highway, Santacruz (East), Mumbai- 400 055, who have placed in our hands your demand letter dated 26 February 2019 (“demand notice”) issued under the Insolvency and Bankruptcy Code 2016 (“the Code”) and have requested us to write to you as under 1. At the outset, our clients deny each and every allegations, contentions, averments, insinuation and purported claim made in the said demand notice and nothing shall be deemed to have been admitted by our clients unless admitted expressly, and further put your client to the strict proof thereof. 2. In meantime, our clients are in process of collecting details of the New Year Event (“the event”) held on 31 December 2018 at China House at Grand Hyatt Mumbai (“the Hotel”), and detail reply to the vexatious statements and baseless invoice issued by your client, very shortly. 3. Our clients state that our clients had appointed Ankytrixx and Friends Entertainment (“the programmer/artist manager”) for providing services of A Behramji Mansion, 4th Floor, Sir P. M. Road, Opp. Kashmir Emporium, Fort, Mumbai - 400 001. Tel. : 6610 0255 / 58 + E-mail: kalpeshjoshi77@ gmail.comperformers/artists and DJs as one point contact for playing music/sounds alongwith their instruments / equipments for the said event held on 31 December 2018. After several oral conversation, correspondences and negotiations, the charges/fees to be paid by our clients for the said event (above services as included) was fixed for a sum of Rs. 1,30,000/- (Rupees One Lakhs Thirty Thousand only), which was duly confirmed with Ankytrixx and Friends Entertainment. The said amount includes all the fees/charges/remunerations for all artists (performers), DJs persons alongwith instruments/equipments for music/sounds and license for playing the music etc. However, there was no individual contract/agreement executed or entered with your client with respect to the above subject. Therefore, the alleged claim made by you on behalf of your client in the said demand notice does not constitute unpaid operational debt due from our clients and hence, the said demand notice is not maintainable on the said ground. It is pertinent to note that our clients have also received three more alleged invoices from Mr. Sanjay Kumar Dutta for a sum of Rs. 70,000/- (DJ charges) under invoice dated 29 December 2018, your client i.e Mr. Jayant Luthra for a sum of Rs. 1,18,000/- (Artist fee for Jitter) under invoice dated 30 December 2018 and Mrs. Divya Samdhani for a sum of Rs. 1,18,000/- (Artist fees) under invoice dated 2 January 2019. However, our clients have already requested the concerned persons through — several. oral conversation and correspondences/emails that under what pretext they have issued such alleged invoices to our clients, but till date our clients have neither received any justification to the said request nor any clarification towards the alleged claims. Moreover, as your client’s purported claim also falls under the above alleged invoices and hence is nothing but an concocted claim created without having any substances in it and is particularly drawn up for deceiving our clients. However, on 4 March 2019 our client wrote a detailed email to Mrs. Divya Samdhani stating that our will require an email confirmation from lawyer ie 2 wyou for withdrawal of said demand notice. Further, the said confirmation should also include that the parties involved in the aforesaid transaction will have no objection towards the release of payment of Rs. 1,30,000/- (Rupees One Lakhs Thirty Thousand only) in favour of Ankytrixx and Friends Entertainment as full and final settlement of the dues of the entire event of 31 December 2018 and of the persons/artists/DJs etc. associated with Ankytrixx and Friends Entertainment. However, on 7 March 2019, our client received an email from you informing our clients that, under instructions from your clients i.e. Mr. Jayant Luthra, you are withdrawing the said demand notice dated 26 February 2019. Our clients state that even after several request, you nor your client have come forward to provide a clear picture in respect of your client's alleged claim as well as the aforesaid alleged invoices issued by the said concerned persons. 6. Therefore, in view of the aforesaid and in view of the said withdrawal email dated 7 March 2019, your client is hereby called upon to provide detailed clarification towards the purported invoices raised by your client as well as the aforesaid concerned persons (DJs/artists) clamming through Ankytrixx and Friends Entertainment. 7. Inthe meantime, your client is also requested to desist from taking any action as mentioned in your demand notice. Yours faithfully Kafpegh Joshi ce. to: Grand Hyatt, Mumbai.