THE KOCHI POST EXCLUSIVE

Regd. With A/D

To
1. (Name & address of the Director)
2. (Name & address of the Producer)

Legal Notice

This notice is issued to you under instructions from my client Meghna

Nair, D/o. address: ******************* Kochi, Kerala.
My client has instructed me that-

She is professionally engaged in media industry for the last more

than five years as an anchor, Video Jockey, Radio Jockey and is the
top-tier performer of three successful ongoing shows on radio and
TV. She is austere in her performance over these years giving
paramount consideration for ethical genre. Her boldness and
benevolence and commitment in her endeavor brought reputation
and notability for her among the viewers and the film crew.

The first among you as the Director and second among you as the
Producer had made a film titled Honey Bee 2 in which my client has
essayed an important role upon your request. She was approached
by one Mr. Anoop V. (Line-Producer) on behalf of the first among you
and upon his request she met the first among you in your house
where you narrated the role and its importance in the film and
requested my client to learn New York English accent for the
character and some dance for performing a break dance in a
wedding reception scene. After you narrated the story, my client
THE KOCHI POST EXCLUSIVE
insisted you to make a contract, for which you agreed and entrusted
Mr. Anoop for further communication in this regard. Further, you
promised to pay my client an amount of Rs. 1,00,000/- (Rupees One
Lakh Only) as remuneration for which my client also agreed. My
client further informed me that after so many days Mr.Anoop called
her conveying the scheduled dates for shooting, but when my client
enquired about the contract and script of her character, he did not
heed to my clients request and informed her that they have every
other option for casting another person for her role. To this, my client
acknowledged the same and told him to cast any person as they
wish and also informed him that she will not play the role.

After this incident, she was contacted by actor Sreenath Bhasi and
asked to reconsider her decision. Upon further request made by Mr.
Anoop on behalf of you, my client agreed to act in your film and
insisted for the agreement. But till the day of my clients shooting, you
hesitated to make any contract and when my client refused to
continue in your film at the shooting day, Mr. Anoop, approached my
client on behalf of you and requested her that a film making is daily
bread for many people and a days shooting expense is huge. He
went to say that if my client refuses to perform her role it will result
huge loss for the entire crew and further informed my client that,
everything will be dealt genuinely even without a written contract. An
oral agreement with the first among you, fixing an amount of Rs.1
lakh as remuneration for her performance, was entered into and
thereafter Mr. Anoop gave the script to my client and explained her
role as per the script. Since my client did not wish to create difficulty
for other fellow workers she agreed to continue in the film.
THE KOCHI POST EXCLUSIVE
After 6 days of her shooting for your film, Mr. Anoop approached her
while she was costumed and touched up for her character by the
costume designer, Mr. Praveen. As per your narration made to my
client regarding her character, she had to sport a tattoo on her arm
and the tattooing process was an extremely tedious one, which used
to take several hours. My client had expressed concerns about this
process but her concerns were not attended to.

While the tattooing process was on, the Assistant Director hurried to
her room and asked the costume designer e dressil ival kuninju
nilkendi vannal enthenkilum kanan pattumo? (Malayalam). My client
was stunned by this statement and asked Mr. Anirudh if he was
referring about her or her character. Upon his affirmation Mr. Anirudh
explained that the scene is like this- my client arrive at the hotel
lobby in a taxi. She gets out and the taxi driver puts her bags on the
floor. She bends down to pick it up- exposing a part of her back and
stomach. When she bends down to pick it up the bags, Asif and
Bhasi would watch this only to realise its her when she turn around.
Her character would be unaware of any of this, see Asif and after
greeting him proceed up to the room. My client informed me that this
scene was newly introduced intending to harm her and with the
knowledge that this will degrade her reputation. She questioned the
same and informed him that she is never going to do such an
indecent and vulgar scene and further informed that such a scene
was not in the script and if it was there she would not have given
consent to act in the film.

The scene that was explained to my client in the morning of the shoot
was one where the character of my client recognises the character
played by Asif Ali by a picture on a mobile phone. At that point of
THE KOCHI POST EXCLUSIVE
time, nothing was told to my client regarding the posture or body
exposure that was planned in that particular scene.

The Assistant Director told her that this was a newly considered
scene and if she is not going to do it, the first among you could
replace a body double instead of my client. My client opposed to this
new development and strongly objected picturing a body-double,
instead of her, in a filthy way as it would make an impression to the
viewers that the scene was done by my client. As my client did not
agree to your demand, you asked my client to leave the set and
informed her that you will convey the next schedule date, as there is
a wedding reception scene to film in which my client has a role.

Thereafter you did not call my client for further shooting. As there
was no information from your side, my client was under the
impression that you would have recast her role in the film or would
have made appropriate alterations to delete the scenes already
taken. It is pertinent to note that, Mr Anirudh had told my client that
she will be contacted regarding the shoot on the 12th of December.
Since there was no information from his part, my client contacted Mr
Anoop, regarding the incidents that took place and also to get an
update about the progress of the shoot. My client informed Mr
Anoop that she had the possibility of a work opportunity, at another
event at the Kochi Biennale, on the same day, and she was available
for shoot. But, Mr Anoop didnt respond on this.

Few months later your film was released. As my client was under the
impression that her scenes might be deleted, she did not watch the
film. Thereafter, few weeks later, my client received phone calls from
her friends, who watched the film- Honeybee 2, intimating her that
THE KOCHI POST EXCLUSIVE
they were shocked to see my client being portrayed in the film and
never thought that she would ever act such indecent scenes in films.
My client was stunned by their propositions and upon enquiry she
realized that her character is there in the film. My client thereafter
saw the film and was mortified upon seeing that you had used a body
double instead of her in the much opposed scene. It was a very
vulgar scene where the entry scene of her character was done by
merely focusing on her butt and thighs, as she was bending- torso
and all- into the front window of a taxi. My client was so embarrassed
and is so depressed upon this incident. You made and published
such a scene only intending to harm my client and knowing that her
character will be individually considered by the audience and it will
gave an impression that she is a girl of less virtue and upon firm
belief that if she is characterized in this way it will defame her
reputation. My client was under the strong belief that even if you had
gone ahead to include her scenes, she should have got the call for
dubbing her portions, especially after you had told my client to
prepare and be well versed in New York accent for portrayal of the
character. But, my client was not called for or informed about the
dubbing. Further, seeming to be complete disdain to my client, a
highly incompetent dubbing artist was used, while my client had
prepared for the same in her own time. It is also imperative to note
that you did not provide my client with an accent coach or a dance
coach for the preparation.

My client contacted Mr. Anoop and expressed her grievance and told
him to ask the first among you to delete the much vulgar scene. But
my clients concerns were not taken care of by any of you. You have
cheated my client utilizing her talent and skill in your film without
THE KOCHI POST EXCLUSIVE
giving any remuneration and presented my client in a vulnerable way
intending to defame the reputation of my client.

After the indecent representation of my client in the movie, she had

to face a lot of mental agony answering to questions raised by dear
and near, people from the media industry, and different other
quarters of life, after the release of the film. The damage was so
severe that it had apparently eclipsed the good name and reputation
my client had built through her relentless hard work and
perseverance in her job, always giving predominant importance of
carrying herself in the most dignified manner.

My client is very much depressed by this incident. The saga of

misery she had undergone cannot be expressed in words. My clients
grievance cannot be compensated in terms of money. As a matter of
relief I hereby call upon you on behalf of my client to make a public
apology and announcement that the girl in the indecent scene is not
my client and to pay to my client an amount of Rupees Ten Lakh as
compensation and an amount of Rupees One Lakh as remuneration
for her performance as was agreed by you, failing which my client will
be constrained to take civil and criminal action against you for which
you and your property alone will be liable.

Dated this the ,..day of June 2017