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20/04/2016

Dear Sir / Madam,

MR GAVIN RAJAH AND GAVIN RAJAH ATELIER CC / MS CHELSEA LIU

We represent Mr Gavin Rajah ("Mr Rajah") and Gavin Rajah Atelier CC ("the
CC").

Mr Rajah has been contacted by you with regard to various posts that appeared
on Facebook and various media articles pursuant to defamatory allegations
made by Ms Chelsea Liu ("Ms Liu") against Mr Rajah. Firstly please note that
this is not her real name but a pseudonym used by her. Ms Liu instituted action
against the CC on 18 March 2016 which action was defended by the CC. Ms
Liu however subsequently withdrew the action on 12 April 2016. Her public
allegation that the withdrawal was as a result of the legal representatives
delaying the matter is untrue. It is clear that Ms Liu did not have prospects of
success to pursue the action and, now having withdrawn the action, has
resorted to utilising social media to defame and damage Mr Rajah's good name
and reputation.

You have requested that Mr Rajah provide you with a statement in response to
these unfounded allegations and this is the statement:

"Gavin Rajah Atelier CC concluded a business agreement with Ms Chelsea Liu during
2015 in which certain monies were paid by her for services rendered by the
corporation. As the representative of the corporation, I confirm that we complied fully
with our obligations which included using images from both ranges to secure
international exposure. The business relationship was unsuccessful and to date Ms Liu
is still indebted to the corporation. Ms Liu instituted legal action but withdrew it last
week. Had she had any basis or prospect of success she would have pursued it. She
however has chosen to withdraw the legal proceedings, which the corporation
defended, and rather utilise social media to defame and damage my good name and
reputation. I outright deny the unfounded allegations. If Ms Liu believed she had a
valid claim she would have pursued it through her legal representatives in South Africa,
which she has not done. It is correct that I addressed an e-mail to her husband, which I
did only pursuant to her malicious posts on Facebook, to inform him, as a courtesy, that
should these defamatory comments not be withdrawn I would institute proceedings to
protect my reputation which may affect her application for citizenship in the USA. I did

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20/04/2016

not attempt to intimidate her or her family and her public comments in this regard are
defamatory, unfounded and untrue.

Please note that should you quote my statement above it should be quoted in
its entirety without deviation, distortion, omission and should be quoted in the
correct context.

Yours sincerely

BRIAN KAHN INC.


Ms Nicqui Galaktiou
Director
nicqui@briankahn.co.za
Direct Line: +27 11 577 5635
Direct Fax to E-mail No: 0865229193
Encl.
(This communication has been electronically transmitted and is therefore not signed)

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