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By Regd Post with Ack-due

Kadapa,
15-09-2018.
From:-
1. Sri.K.Venkata Reddy B.Com., B.L
Advocate
Door No:-2/476 Nagarajupet,
Kadapa city post and District.

2. Sri.M.Ramanjaneya Reddy M.A., B.L


Advocate
Door No:-2/468-1 Up stares,
Nagarajupet,
Kadapa city post and District.

To:-
Sri.Y.Chandra Sekhara Reddy,
Advocate
Door No:- ,Near Saibaba temple,
Panjagutta, Hyderabad city.
Cell No.9440890488.
Sir,
Sub:- Legal notice for damages of Rupees two crores and criminal
prosecution – Rg.
1. You drafted plaint in O.S No.43/2017 pending on the file of
FOURTH ADDL DISTRACT JUDGE COURT AT KADAPA by making false
pleading by attributing unpleasant allegations against us which are not
at all instructed to you by Kumari Bhargavi. You drafted those
pleadings as per your whims and fancies for wreaking vengeance
against us. The said pleading what you drafted in O.S No.43/2017 are
beyond your limits and beyond the ethics and provisions of advocates
Act. The said plaintiff Kumari Bhargavi was not an eye witness and she
was not a party to M.C No.3/2014, DOP No.20/2016, TOP No.339/2014
and Criminal Transfer Petition No.1500/2014 and that Kumari Bhargavi
was not concerned with those pleadings and that woman was not
present in all those four courts at the time of agreements and that
Kumari Bhargavi did not see the pleading in those four cases. So that
Kumari Bhargavi did not instruct you to write pleadings in O.S
No.43/2017 suit plaint as well as pleadings in rejoinder dated
09-11-2017 since you pleaded in suit plaint and rejoinder with malafide
intention.
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2. The allegations made by you in the suit plaint of O.S
No.43/2017 and rejoinder dated 09-11-2017 are totally false which are
causing damage to our reputation in the Bar association of Kadapa as
well as in other Bar Associations and among the clients. The said
allegations made by you are personally attacking our prestige and
reputation before the public as well as before advocates in general.
Why should you are personally attacking us even though we wrote
such pleadings as pleaded in M.C No.03/2013 on the file of JFCM
RAJAMPETA. The pleadings in O.S No.43/2017 suit plaint and in
rejoinder in O.S No.43/2017 are originally emanated from you without
the instructions of your client Kumari Bhargavi because you are native
of Kadapa district, practiced for some time in Kadapa courts and got
properties in Kadapa district. You also got close Kith and Kin and close
friend’s practicing in Kadapa district courts.
3. The rejoinder petition I.A No.1471/2017 affidavit was not
signed by Kumari Bhargavi since that signature is 100% differing from
her signature found in suit plaint. The Vakalat filed in O.S No.43/2017 is
containing the names of advocates 1). J.Pullaiah, 2). Y.Chandrasekhar
Reddy, 3). G.Kalyana Reddy and 4). Rama Gangi Reddy. Later your
name and 2 other names were struck off by Keeping J.Pullaiah as scape
goat for all your false pleadings. The rejoinder docket dated 09-11-
2017 is containing the name of you as M/s Y.Chandra Sekhar Reddy
and associate-advocates, Hyderabad and also the name of
Sri.R.Chandra Obula Reddy Advocate Kadapa is found in that docket.
4. We gave first legal notice dated 09-01-2018 to Sri.Pullaiah
and Sri.R.Chandra Obula Reddy both advocates of Kadapa by
demanding them to give reply notice to us as to who drafted pleadings
in O.S No.43/2017 suit plaint and also in rejoinder in O.S No.43/2017.
The said advocates received that legal notice and utterly failed to give
reply notice to us. We issued second legal notice dated 21-05-2018 to
Sri.J.Pullaiah and Sri.R.Chandra Obula Reddy both advocates of Kadapa
by demanding them to give reply notice to us as to the fact who
drafted the pleadings in suit plaint in O.S No.43/2017 and rejoinder
dated 09-11-2017. Sri.J.Pullaiah advocate of Kadapa did not give any
reply notice to us for our two legal notices. Sri.R.Chandra Obula Reddy
advocate of Kadapa now appearing for the plaintiff in O.S No.43/2017
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gave a reply notice dated 20-07-2018 by stating the he did not prepare
and did not draft the pleadings in the rejoinder dated 09-11-2017 since
you are the author of O.S No.43/2017 suit plaint and also rejoinder.
The reply notice of Sri.R.Chandra Obula Reddy advocate stated that he
did not draft the rejoinder and petition thereof, and that he simply
signed and filed it in the court. We are unable to understand the
motive, purpose, of your mind for sprinkng mud on us. We never
raised our voice about your honesty and about your properties or
personal things at any point of time. In fact we have no connections
with you at all at any point of time, but we are surprised to know that
what made you to speak and teach so much of ethics, morals and
professional conduct etc. We honestly believe that a man, who lives
honestly & morally, can give lectures, teach ethics, morals and
professional conduct. There is nothing wrong. Thus a man who speaks
ethics so much, must have conscious of his own honesty, ethics etc.
5. Therefore please take this legal notice and that you
voluntarily drafted pleadings in O.S No.43/2017 suit plaint as well as
the pleadings in the rejoinder dated 09-11-2017 filed in O.S
No.43/2017 without the instructions from Kumari Bhargavi by
personally attacking our prestige and reputation and that you are liable
to pay Two crores to us within 10 days towards damages, and that you
are liable for criminal prosecution. Otherwise we are forced to take
appropriable civil and criminal proceeding against you in the court of
law by holding you liable for costs and consequences.

ADVOCATES

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