To,

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. Deal 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. The order copy dated 04.01.2017 is
annexed herewith for your record and reference.

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 inquirty they informed that they are inspecting for the valuation
purpose as Mr. Lisbon Pascal Colaco and Ivy Lisbon Colaco, partners
of M/s. Deal 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.___ that
by suppressing the true facts and material Mr. Lisbon Pascal Colaco
and Ivy Lisbon Colaco has submitted loan application (as per the
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 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