NEGLIGENT CONDUCT BY ANZ BANK AND ITS AGENTS

January 18, 2024

Your Ref: TBA
Our Ref: [Insert Ref] please quote our reference when replying
Priyal Tharanga Gunawardana Mudalige
[Insert Place of Residence]
[Insert address]
[Insert Country/State]

RE: NEGLIGENT CONDUCT BY ANZ BANK AND ITS AGENTS
Reference is made to the above matter and I address you as hereunder:
That on or around March of 2021, you approached [insert name of bank] with an application to
refinance my existing loan in order to obtain a new loan facility with the intention of purchasing a
parcel of land that was being sold at $440,000.00. That I was assigned an officer named
Abhishek Gupta, who had the responsibility of communicating with myself to enable the
seamless processing of my application.
That upon receipt of the pre-approval letter from the bank’s officer, I duly complied with the
conditions and forwarded the requested information to the bank officer for processing. The bank
officer subsequently gave me the ‘go-ahead’ to make offers for the purchase of the parcel of
land. I thereupon made an offer of $440,000.00 to the land vendor, who accepted the offer.
Regrettably, the bank failed to provide the finances at the agreed time, causing the vendor to
cancel the offer. I later discovered that the officer that had been assigned to me had been let go
due to a lack of experience and adherence to bank procedures. The bank thereafter assigned
two officers to work on my file. I then received the bank’s new approval letter three months after
the initial approval.
Due to the negligence of the bank and its agents who were in the course of duty, I was forced to
incur an extra cost of $35,000.00 for the purchase of the same piece of land, and $50,000.00 –
$70,000.00 for the construction of the house with increased prices.
That despite constant complaints, reminders and follow up, you have failed /refused/neglected
to adhere to my request to remedy the situation as caused by your negligence. Accordingly, my
strict, unequivocal and concise instructions are to DEMAND from you, which I hereby do, your
immediate admission of fault and reimbursement of $85,000 within Fourteen (14) days of
receipt of this email.
TAKE NOTICE that unless the aforesaid demands are met within fourteen (14) days from
receipt of this email, I shall institute legal proceedings against you and at all times, holding you
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.

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