Legal Notice Against Fakhra Hassan, Nighat Dad, Meera Ghani and DRF

                                                                                                                                         1/29/2013

                                                                                                                           Without Prejudice                                   

To:

1.      Fakhra Hassan

2.      Nighat Dad

3.      Meera Ghani

4.      Digital Rights Foundation  

Via Courier/Web-Publication/Email 

Legal Notice

We act for Yasser Latif Hamdani- a lawyer and an activist for the internet transparency and freedom- (“Our Client”) who has instructed to address you as follows:

1.      That Our Client is a lawyer and an activist for, inter alia, net freedoms, access to internet for all and for women’s rights who has built his reputation through painstaking hard work and utmost integrity and sincerity of purpose.

2.      That you have engaged in certain defamatory and untrue communications with the board members of [Name of the Organization Omitted for Privacy], a leading international organization, as well as on Facebook, an international social network, with the sole intent of defaming and discrediting our Client.  In the process you also lied about the proceedings of a court case that Our Client has initiated against three individuals. It is submitted that you knowingly misrepresented the proceedings as being against Our Client when this is not true. It is further submitted that you deliberately and maliciously concocted a story regarding Our Client to hurt Our Client’s work and reputation and to ostracize Our Client internationally.

3.      That you have done so with foreknowledge that all of your claims are untrue, incorrect and patently false, including the representations you made as under:

a.      That Our Client is engaged in any sexual harassment or anti-women behavior on the internet including against some female activists of take back the tech.

b.      That Our Client has made rape threats against Nabiha Meher Shaikh, who is Defendant No. 1 in Our Client’s Lawsuit before the District Judge, Lahore. It is of special relevance as Ms. Shaikh has admitted in her rejoinder in the said lawsuit that no rape threats were made against her.

4.      That of the aforesaid communications and other slanderous utterances against Our Client we have documentary evidence as well as witnesses who will testify in court that you slandered Our Client in their presence.

5.      That you have damaged not the reputation of Our Client but have irreparably harmed Our Client’s work with a mala fide intent.

6.      That your communications with [Name of the Organization Omitted as aforesaid] Board and on Facebook has irreparably harmed the reputation of Our Client globally for which you have to be held accountable.  

7.      That you are required to cease and desist from any further such communications containing defamatory statements against Our Client with immediate effect.

8.      That you shall write to the [name of the Organization omitted as aforesaid] and retract your mala fide statement and inform them that you had done so only to hurt Our Client’s reputation and that you shall tender an unqualified apology.

9.       That you pay to our Client damages for loss of reputation, pain, hurt, anguish and mental torture caused by your irresponsible, malicious and defamatory email communication , a sum of Rs. 100, 000, 000 (One Hundred Million Rupees).

10.  That the foregoing conditions, contained in clauses 7, 8 and 9 are sine qua non and irreducible minimum to be fulfilled within fourteen (14) days.

11.  That the failure to do so shall leave our Client no choice but to take legal action on every forum of competent jurisdiction, including civil and criminal courts.

12.  A copy of this notice is retained in our office for record.

Rana Muhammad Aurang Zaib Khan

Advocate High Court