SHASHI PRAKASH Office Address: Flat No.

01, Mahavir Jyot CHS,

Advocate High Court Vishal Nagar, Nr. Manikpur Police station,
Vishal Nagar, Ambadi Road, Vasai West,
Taluka: Vasai, Maharashtra-401202.
Office Contact: 9890857433.
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To, Date: 27th February 2024
The Manager/Board of Directors,
Bassein Catholic Co-Op Bank Ltd.(Head Office),
Umelman, Vasai West, Vasai-Virar,
Mulgaon, Maharashtra 401202.

Ref. (1) Survey No.1 (old 14), 3 (Old 60), 13 (old 15), total
admeasuring 15410 sq. ft. situate at-Village-Vasai, Palghar.
(2) Letter dated 28.04.2023, having inward bearing No. I/W-6903
dated 28.04.2023.

Sir/Madam,
Under instructions and on behalf of my client Mrs. Annie Joseph
Miranda, Having address at-Dhar Bhat, Near Chandkadi Devi Mandir,
Kiravali, Vasai (West), District: Palghar-401 202. I have to address
you as under:-

1. My client states that she and her husband viz., Late Joseph
Miranda are the real owner of property having Survey No.1 (old
14), 3 (Old 60), 13 (old 15), total admeasuring 15410 sq. ft.
situate at-Village-Vasai, Palghar (Herein after referred as said
Property) and having ownership documents in their favor.

2. My client states that in the year 2011, Mr. Lisbon Pascal Colaco
and Ivy Lisbon Colaco, partners of M/s. Leal Developers, hatched
an criminal conspiracy and prepared bogus fabricated and false
 Sale Deed having documents bearing No.10418/2011 by putting
fabricated thumb impression of my client. That my client has
registered and/or initiated criminal proceeding before Vasai
Police Station as a FIR No.03/2020.

3. My client states that she has also filed Civil Suit bearing
No.150/2016 before Vasai Court for cancellation of said above
alleged documents No.10418/2011 and till the date matter is sub-
judice, that Hon’ble Court was pleased to allow the Injunction
Application in my client’s favor and restrain the Accused person.
a
4. My client states that on 27.04.2023, your bank officials criminally
trespassed in my client’s plot of land for inspecting and valuation
and upon inquiry they informed that they are inspecting for the
valuation purpose as Mr. Lisbon Pascal Colaco and Ivy Lisbon
Colaco, partners of M/s. Leal Developers, have filed loan
application to your bank. That on 28.04.2023, my client informed
you regarding pendency of Civil Suit and Order, but till the date
you have not responded to the said letter.

5. My client states that she has also filed Writ Petition for
cancellation of the C.C. pending before the High Court as a Writ
Petition No. 8996/2023, that by suppressing the matrial and true
facts, Mr. Lisbon Pascal Colaco and Ivy Lisbon Colacohas
submitted loan application (as per the oral information of bank
officials ), so, I am hereby requesting you that please do not
consider/entertain/grant loan application without proper
verification/analysis of paper and proceeding, otherwise you will
render yourself for criminal contempt of court or criminal
offences.
Under the aforesaid circumstances my client has instructed me to call
upon you and require you, which I do hereby, call upon and request
you that not to proceed any loan application on my client property and
kindly reject the same if any pending, failing whereof my client shall
initiate appropriate legal action against you.
I hereby lastly requesting you that please reply, & acknowledge the
letter.

Coy of this notice is retained in my office for further legal action.

Please receive and acknowledge the same.

Signature of Client. Adv. High Court.

Mrs. Annie Joseph Miranda
.