To,

Date: 12.10.2016

Shri Kuldeep Singh Balhara,

Pocket A-1/360A,
2ND Floor Rohini
Delhi-110085

Sub:

Your Legal Notice dated 16.06.2016 issued on behalf of your client Sh. Kuldeep
Singh Son of Sh. Dilbagh Singh resident of House No 45, Sanskrit Apartment
Opp. North Ex Mall Sector 14 Rohini-110085.

Ref: Supplementary Reply on behalf of M/S. SERA CUE LABS Pvt. Ltd.
Dear Sir,
Apropos of your legal notice dated 17.06.2016 and reply dated 27.07.2016 thereto by our
client M/S. SERA CUE LABS Pvt. Ltd sent through Shri Manish Kakkar, Advocate. It is
further stated as under:
1. That such contents of your notice dated 16.06.2016 as are baseless,
unfounded wild and imaginary have already been denied by our client
vide its reply dated 27.07.2016.
2. That it is a strange case of the kettle calling the pot black. Your client
Kuldeep Singh is the actual wrong-doer who is trying to arm-twist the
directors and officials of M/s Sera Cue Labs Pvt. Ltd and he wants to
extract huge money from them.
3. That the matter is purely of civil nature and arises out of the
contractual rights and liabilities of the parties. Your client cannot be
allowed to walk and talk beyond the terms of the Franchisee
Agreement. In case of violation or breach of the terms, the aggrieved
party can have recourse to such remedies as are available under the
Franchisee Agreement. In case of any irreconcilable dispute, the parties
have to have recourse to arbitration as provided by clause 13 of the
Franchisee Agreement between the parties.
4. That the arbitrator proposed by your client was not accepted by our
client. Our efforts to amicably resolve the matter have failed. Thus, we

are left with no alternative but to have recourse to arbitration clause as

incorporated in the Franchisee Agreement. Now for appointment as
Sole Arbitrator, we propose the following names:
(a) Shri Vinod Jain,
District & Sessions (Retd.)
House No.381, Sector 1,
IMT, Manesar, Gurgaon, Haryana
Mobile: 9468178585
(b) Shri S.K. Goel,
District Judge, family Court (Retd)
House No. 85, Sector 56,
Gurgaon, Haryana
Mobile: 9999575603
(c) Shri Ashok Bhardwaj,
Addl. District Judge (Retd.)
House No. 30, Birch Street, Malibu Town,
Sector 47, Gurgaon, Haryana
Mobile: 9818039966
You are hereby requested to ask your client to approve any one of the above name to
decide the dispute between the parties. A copy of this supplementary reply has been
retained in our office for record and for necessary use.

Dr. Shiva Sharma,

Advocate
Copy forwarded for information and necessary follow-up action to Kuldeep Singh, House No
45, Sanskrit Apartments, Sector 14, Rohini, and Delhi 110085.