Xxxxxx Xxxxx, Advocate High Court, Punjab, Pakistan

+92-(0)-33333333 xxxxx@gmail.com Mozang Road, Lahore

To:
Ch. Khurram Qayyum, Advocate,
Bader and Bader Law Associates, Mozang Road, Lahore

Copy:
xxxxxx
xxxxxx Technology, Johar Town, Lahore

RESPONSE to CLAIM AND NOTICE of COUNTERCLAIM

My client, Muhammad xxxx son of Muhammad xxxxxxx, is in receipt of your “Legal Notice” dated 14
September 2019. Here is the point by point response:
1. The facts in point 1 are correct and my client complied with the notice period. He presented his
written resignation on 21 June 2019 and informed that his last working day will be 5 August
2019. Proof will be presented in court. There was no written response from your client.
2. We dispute this point.
3. My client started his new employment on 6 August, and then returned for 2 additional days – 7
and 8 August 2019 – to accommodate your client’s presentation appointment. You mention 30-
day notice, which contradicts 45 days mentioned in (1). We dispute the rest of this point.
4. We dispute this allegation. We have written correspondence from a xxxxxx manager stating
that they will be closed for about 10 days due to Eid-al-Azha holidays. No data was kept on the
laptop. All code and artifacts are stored in remote storage in the ‘cloud’.
5. We vigorously dispute this point. This claim is frivolous and vexatious.
You fail to mention the PPC section under which you plan to launch criminal proceedings.
My client is owed salary, compensation in place of holidays, provident fund payout as well as legal fees.
The sum of these will exceed PKR 250,000. We plan to go to court to recover this as well as any
subsequent defamation and punitive damages.
We have apology, in writing, from your client to my client for unprofessional behavior due to which he
was looking for another job. Your client has also threatened my client with defamation at his new place
of employment. This was well-known within your client’s place of employment.
Please forward PKR 250,000 within a fortnight to my client to avoid legal proceeds. Please conduct
yourself accordingly. In case xxxxxx is no longer in an executive position at xxxxxx, please forward this
response to the current relevant executive at xxxxxx Technology. All witnesses together with other
evidence will be presented in court.

Sincerely,