10 June 2023

Dear NAME,

Defamatory Statement

I refer to your letter dated DATE, complaining that I have published defamatory statement.

1. By the said letter, you asserted that I have published defamatory statement, in a CONTEXT (“Statement”). The Statement was a private and confidential conversation between myself and my friend. I have not published, nor shared, the content of the Statement to any other third parties on any other occasions. The publication of the Statement to third parties alleged by you is entirely misconceived.

2. For reasons set out below, my Statement was “justified” as true or substantially true. And in so far it consisted of expression of opinion, it was “fair comment” on a matter of public interest, not actuated by malice, and based on facts that I honestly believed was true.

3. FACTS_TRUE FAIR_COMMENTFurther, as evidenced by a [document] dated [Date] provided by you, I have bona fide and substantial ground to believe that the said [document] was a forged document. I honestly believe and had reasonable grounds to suspect, that you did not act in good faith.

4. I have acted in a fair and equitable manner. Your allegations are simply wrong and disingenuous.