January 13, 2024

Your Ref:
[Insert name of recipient]
[Insert address of recipient]
[Insert recipient telephone number]
I, Keisha Odutayo, write this letter as a representative of my husband, Adebayo Odutayo, under
whose authority I address you as hereunder;
That on or about October of 2015, your client, Judd Feinman entered into a contract for the
sale of Four properties with my husband, the said Adebayo Odutayo, which contract was to be
concluded on or about August 2020. That your client facilitated the drafting of the contract,
which was executed by both you and Adebayo Odutayo.
That you denied Adebayo Odutayo the chance to read through the contract and have it
examined by an attorney of his choosing, which, in hindsight, showed your intent to defraud
Adebayo with the contract. That you went on to read the contract to him and refused to show it
to him until he had executed it. This went against Mr. Adebayo Odutayo’s rights under the law,
including his freedom of information and rights to property.
Additionally, your client continued to encumber the property with loans and liens during the term
of the agreement by using the property as collateral to a bank to access loans, unbeknownst to
the buyer and the bank. These actions went against Section 13 of the contract between your
client and Mr. Adebayo Odutayo, which assured us of the seller’s good and marketable title, in
which there are no liens and encumbrances. The section also stated that neither party shall
alienate the title to the property at any time during the term of the agreement. Your client’s
actions therefore constitute a breach of a major term of the agreement concluded between him
and Adebayo Odutayo.
Furthermore, your client intentionally misrepresented material facts in the contract, went against
the national and international trade practices that require good faith and fair dealing, and
intentionally plotted to defraud the buyer of the sum of around 400,000 dollars. With this in mind,
your client is liable for both civil and criminal offense and shall be liable as such.
That despite our constant complaints, reminders and follow-up, your client
failed/refused/neglected to acknowledge wrongdoing and bad faith on his part. Accordingly my
strict, unequivocal and concise intention is to DEMAND from your client, which I hereby do, his
immediate admission of fault, a full and unqualified apology addressed to Adebayo Odutayo and
compensation for the intentional misrepresentation of material facts of the contract in the sum of
[Insert amount] Fourteen (14) days of receipt of this letter.
TAKE NOTICE that unless the aforesaid demands are met within fourteen (14) days from
receipt of this letter, I have preemptory and mandatory resolution to institute legal proceedings
against your client in civil and criminal court and at all times, holding him liable for costs and
other consequences ensuing therefrom. I trust that this will not be necessary and look forward to
your urgent response. Be advised.
Yours Sincerely

Keisha Odutayo

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