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From: Date: 14/Dec/2023

1.Sh.Ram Sewak Ojha

2.Sh.Vinod Ojha

For both

R/O. A-527/1 Kartar Nagar IV Pushta Gali No.1 Delhi-53

To,

Sh.N.K.Singh Bhadauria (Advocate)

Off: Chamber No.D-316,

D-Block, Karkardooma courts

Shahdara, Delhi-110032

His

Client : Smt.Anita Devi

W/O Sh.Surender Singh

R/0 E-399 , 20 Foota Road Karawal nagar Delhi-94

Title:

Response to the legal notice (by aforementioned N.K Singh Bhadauria on behalf of his client dated 7th
December 2023) sent to us in written.

Request is to please consider this letter as the legal response to the legal notice sent to us.
Sir,

With due respect, thanks for bringing this partition notice to our attention for the first and only time by
by you on behalf of your client through any means of communication.

We do hereby state that all the claims and allegations raised against us in the legal notice are totally false
and spurious.

The allegations raised about the nature and personality of us by your client is because your client has
deceitful and malafide intentions to harass us mentally and financially.

The land on which you and your client is asking for partition only belong to us legally since last 27 years.

We state that this is the first and only time we are hearing the property share matter from your side
through any means of communication but your client Smt. Anit Devi has repeatedly made several
extortions to us in past 35 years and have gained a good amount of money using those deceitful
techniques on various other grounds also.

Your client Smt.Anita devi do not have any kind of share from the property per the Hindu succession act
(56 amendment 2005) or Indian succession act.

We deny to the give her any kind of share on the land/property because there is no legal attachment of
property to your client and it only belong to us.

You and your client are sincerely and respectfully free to go head with the legal proceeding per the
wish and willingness of the client Smt.Anita Devi but the cost and risk involved in future legal
proceedings will only and only be bear by your client.

We deny to accept any kind of cost involvement of future legal proceedings from your side in addition
we also deny to accept the cost of Rs. 11,000 as mentioned in the legal notice sent by you on behalf of
your client Smt.Anita Devi.

We hereby sincerely request and state that we are not willing neither capable of bearing any cost of legal
proceedings so also we are not legally liable to this compulsion.

It's only you and your client Smt. Anita Devi’s wish to go ahead with legal proceedings thereafter we
have no other option to defend from our side under the law in court.

We also sincerely deny to share any documents in original or in xerox or through any other mode of
communications with you or your client Smt.Anita Devi.

Pardon us but we are unable to do so as we do not feel safe to go ahead for the same because your
client has malafide intentions to get money from us and any document can be used in wrong manner
from your client Smt.Anita Devi.
Your client Smt. Anit Devi has repeatedly made several extortions to us in past 35 years and have
gained a good amount of money using those deceitful techniques but as we are no longer financially
healthy and also not physically good hence we do not wish to get extorted any more.

We are now on the mercy of God.

He again state that it's only you and your client Smt.Anita Devi wish and willingness to go ahead with
legal proceedings ,due to our bad present conditions (both financially and physically) , we are not willing
to go ahead with that and we sincerely request for that also but it all depends on your client.

We hope that we were able to answer your legal notice properly, in case we missed out anything please
pardon us.

Ram Sewak Ojha Vinod Ojha

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