ACCOUNT_JOB_COMPANY

ACCOUNT_JOB_ADDRESS_SINGLE_LINE

To FIRST LAST, 

[Address]

BY REGISTERED POST AND BY EMAIL (e-mail: [E-mail])

30 April 2024

 

Dear [Title] LAST,

Claim for Fraud on Promissory Note

1. We are making a claim against you for a breach of the Promissory Note (defined below).

2. For reasons set out below, we are a victim of your fraud for our shares in the COMPANY which was replaced by an unsecured Promissory Note.

3. To elaborate, by a memorandum of agreement dated [DATE] (“Share Purchase Agreement, we (as vendor) agrees to sell and you (as purchaser) agrees to purchase the shares in COMPANY (“Company”). 

4. Specifically, under the Share Purchase Agreement:

(a) Clause [x] provides that, you shall pay CURRENCYAMOUNT; and 

(b) Clause [y] provides that, the Completion Amount shall be satisfied by you in the following manner: CURRENCYAMOUNT shall be paid by you on [COMPLETION DATE].

5. By [DATE], you indicated to us that you did not have sufficient cash flow to make full payment of the Completion Amount. 

6. You defrauded us by promising that you will repay the outstanding balance of the Completion Amount by issuing a promissory note dated [DATE] (“Promissory Note”) in favour of us.  Under the Promissory Note, you (as maker) owe to us (as promisee) a sum of CURRENCYAMOUNT (‘Debt’).

7. Specifically, under the Promissory Note:

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