R.C. PAUL KANAGARAJ, B.L.,

ADVOCATE

To     Date: 22-04-2023

Mr. Richardson Wilson

Advocate

JVL Towers, 3rd Floor

No. 51/G5-3A, Nelson Manickam Road Chennai- 600 029

Sir,

Ref:- Legal notice dated 19/04/2023 on behalf Of Thiru. Udhayanithi Stalin

The above referred notice has been placed in my hands by Our client Thiru. K. Annamalai, S/o Kuppusamy, having office at ‘Kamalalayam’, Vaidyaraman street, Parthasarathipuram,

T.Nagar, Chennai-600 017, with instructions to reply as under:-

1. Our client denies all the statements in your notice except those are specifically admitted hereunder and your client is put to strict proof of the same.
2. Our client at the outset states that the all the statements by him in the interview which is the subject matter of the notice under reply were made by him bonafide, in larger public interest and to create awareness about the actual facts and figures among the common public. There is absolutely no violation of any law of defamation as sought to be alleged in your notice. The notice is nothing but a feverish attempt to somehow or other prevent the people from knowing the facts, figures and truth, which was the subject matter of Our clients interview and a peevish attempt to subvert and suppress Our client from voicing the truth by threatening legal proceedings. Your client may well be advised that Our client stands by the statements made by him, and has made the statements with all responsibility in the larger public interest of knowledge to the public, and after due diligence as to the correctness of the facts and figures.

Chamber : 177, New Additional Law Chamber, High court Buildings, Chennai 600 104. Residence •. 2130, Lettangs Road, Vepery, Chennai 600 007. e-mail

Mobile paulkanagaraj16@gmail.com98400 7        7 94443 75747

. . 2 . .

3. Our client denies that your client was a SUCCessful actor, producer and that he set up a highly successful productiOn house• Our client states that the so-called success of your client in the film industry was only OWing to Your client’s political background and family connection• Your client has abused his family’s political power to the advantage of his production house• Our client states that the production house was always used for laundering the money generated through corruption. It is denied that your client has put in any hard work Or commitment in the film industry. The fact that your client resigned from the P rOduction house shows that he now wants to disassociate himself from the dirt involved in his business. However the fact remains that it is your client who was and is the moving force behind the production house and its illegal activities.
4. Our client denies that your client has drawn praise from any quarter for his work as MLA and Minister. It is denied that your client is working hard for the welfare of his constituency. Our client says that your client is not enjoying any reputation amongst the public but.is only enjoying power inherited from his family connection with no merit involved.
5. Our client states that the press conference given by him on 14th April, 2023 was part of his ongoing bonafide effort in larger public interest to create awareness about the various misdeeds of your client’s party and sensitize the people of Tamil Nadu to the issue of corruption. Hence it is denied that there is anything offending in the interview as the statements were made for public good and my client is fully entitled to publicize the same. My client denies that the statements are defamatory or imaginary. MY client has made them after due diligence and will not be cowed down by your threats.

R.C. PAUL KANAGARAJ, B.L.,

ADVOCATE

. .3..

6. Regarding the averments in para 5, our client states that he maintains the highest standards of ethics in politics and would do nothing to invade the privacy of innocent children. The names of your client’s children were mentioned as part of your family tree only because you had disclosed assets belonging to your children in your election affidavit. There is no question of violation of privacy when their photographs or personal details were not shared & my client practices the highest standards of morals & ethics and has not disclosed the photographs of anyone who is/was not holding a public office. Our client states that your client is using the bogey of child rights and privacy to hide his wrongdoings. Our client cannot be silenced by such frivolous threats. Any action taken by your client including before the commission for protection of child rights will be suitably defended by our client.

• Regarding the averments in para 6 and 7, Our client reiterates the valuation of “Red Giant Movies” is rupees 2010 crores and this should be treated as part of the client’s assets. Our client will disclose the necessary material in support of the statement before the appropriate authority. Our client denies that the reputation and value of Red Giant Movies was built on business acumen and hard work of your client. It was built purely based on your client’s family connection and abuse of political power.

8. Our client states that the attempt to distance Thiru. Udhayanidhi Stalin from the said company ‘Noble Steels’ is totally mischievous. The company Noble Promoters Private Limited in which Thiru. Udayanidhi was director and Noble Steels have common directors and are clearly related to each other. Therefore your statement that Noble Promoters Pvt Ltd is not in any way connected to the Dubai company which signed

the MOU with Thiru. Stalin is totally baseless. It is not only because of the common word ‘Noble’ that the allegation was made but because of the personal interest Thiru.Stalin and Thiru.Udhayanidhi Stalin have in these transactions. It is denied that the allegations are a figment Of our client’s imagination. Our client is in possession of

Mobile : . paulkanagaraj16@gmaiI.com98400 75747, 94443 75747

all relevant materials to show the connection between both the “Noble” companies and will produce the same at the appropriate stage

9. Our client states that your notice is nothing but an attempt to muzzle his voice. Our client denies he has committed any offence. There is no question of rendering any apology or paying damages• Our client states that if at all anyone has to pay anything, it is your client and his family members who have to return all their illgotten wealth back to the people Of Tamilnadu. Rather than accepting the legal and moral responsibility for the various acts Of corruption, your client has attempted to use the law of defamation •to intimidate and silence my client and prevent an open discussion on an issue of immense public interest. Our client states that by claiming such fanciful amounts as compensation your client wants to not just sensationalize the issue and deflect public attention.
10. My client also wishes to point a recent development which completely corroborates my client’s stand. The Finance Minister from your own ruling client’s party, Thiru. PTR Palanivel Thiaga Rajan has been recently recorded to have said in a conversation with the journalist that “both Udhay [Udhayanidhi Stalin, minister and son of Dravida Munnetra Kazhagam head and Chief Minister M.K. Stalin] and Sabreesan [V. Sabareesan, the CM’s son-in-law] have realised, they have made more money than their grandfather in a year… they have made Rs. 30,000 crores in a year and they do not know How to handle it…” This clearly shows that there is complete truth in the statements made by my client regarding the DMK party and the family that runs it.
11. In spite of, the above, if your client ventures to initiate any action against my client, the same shall be suitably defended by my client at your client’s risk and cost.

Date: 22-04-2023

Place: Chennai