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    Letter To Embassy of Montenegro - 13-03-2020

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    lu cucu
    The letter is a request from Brand Potgieter Incorporated, a law firm in South Africa, to authorities in Montenegro for evidence in a civil lawsuit regarding a travel company that failed to obtain required visas. It provides details of the lawsuit and parties involved. It requests confirmation of visa applications for 3 individuals, reasons for refusal of the initial applications, and copies of all visa applications. It attaches translated documents to accompany the request, and requests the evidence be provided as soon as possible given the legal proceedings date of May 27, 2020.

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    Letter To Embassy of Montenegro - 13-03-2020

    Uploaded by

    lu cucu
    172 views4 pages
    The letter is a request from Brand Potgieter Incorporated, a law firm in South Africa, to authorities in Montenegro for evidence in a civil lawsuit regarding a travel company that failed to obtain required visas. It provides details of the lawsuit and parties involved. It requests confirmation of visa applications for 3 individuals, reasons for refusal of the initial applications, and copies of all visa applications. It attaches translated documents to accompany the request, and requests the evidence be provided as soon as possible given the legal proceedings date of May 27, 2020.

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    Letter to Embassy of Montenegro - 13-03-2020

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    The letter is a request from Brand Potgieter Incorporated, a law firm in South Africa, to authorities in Montenegro for evidence in a civil lawsuit regarding a travel company that failed to obtain required visas. It provides details of the lawsuit and parties involved. It requests confirmation of visa applications for 3 individuals, reasons for refusal of the initial applications, and copies of all visa applications. It attaches translated documents to accompany the request, and requests the evidence be provided as soon as possible given the legal proceedings date of May 27, 2020.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    172 views4 pages

    Letter To Embassy of Montenegro - 13-03-2020

    Uploaded by

    lu cucu
    The letter is a request from Brand Potgieter Incorporated, a law firm in South Africa, to authorities in Montenegro for evidence in a civil lawsuit regarding a travel company that failed to obtain required visas. It provides details of the lawsuit and parties involved. It requests confirmation of visa applications for 3 individuals, reasons for refusal of the initial applications, and copies of all visa applications. It attaches translated documents to accompany the request, and requests the evidence be provided as soon as possible given the legal proceedings date of May 27, 2020.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 4

    Our Ref: C POTGIETER/AJ ARNOLD/MB0278

    Your ref: MONTENEGRO – EMBASSY OF MONTENEGRO (ATHENS) – No: 02-02/9-4


    Date: 13 March 2020
    Email: [email protected]
    [email protected]

    To: Montenegro – Embassy of Montenegro in Athens


    Email: [email protected]
    Address: Loukianou 5,
    10675 Kolonaki,
    Athens.

    To: Montenegro – Ministry of Justice


    Email: [email protected]
    Address: Vuka Karadžića 3,
    81000 Podgorica.

    To: Department: Justice and Constitutional Development


    Attention: Director-General
    Email: [email protected]
    [email protected]
    [email protected]
    Address: SALU Building,
    316 Thabo Sehume Street, (c/o Thabo Sehume and Francis Baard Streets),
    Pretoria,
    0181.

    Dear Sir/Madam,

    RE: REQUEST FOR EVIDENCE ABROAD FROM MONTENEGRO


    PARTIES TO PROCEEDINGS: JUSTIN MELVILL MCLEOD (PLAINTIFF) // 360
    DEGREES TRAVEL (PTY) LIMITED (FIRST DEFENDANT) // RIDE AWAY
    MOUNTAIN BIKING AND CYCLING TOURS CC (SECOND DEFENDANT)
    COURT: HIGH COURT OF SOUTH AFRICA, GAUTENG LOCAL DIVISION,
    JOHANNESBURG
    CASE NUMBER: 40558/2017
    REQUESTING PARTY: SOUTH AFRICA – DEPARTMENT OF JUSTICE:
    DIRECTOR-GENERAL
    EXECUTING PARTY: MONTENEGRO – MINISTRY OF JUSTICE - MINISTRY
    OF FOREIGN AFFAIRS AND/OR HOME AFFAIRS

    1. The above-mentioned matter as well as your correspondence dated the 22nd of


    April 2019 refers.

    2. As previously indicated, we act herein on behalf of Mr. Justin Melvill McLeod


    (“the Plaintiff”) who has instituted civil action proceedings against 360 Degrees
    Travel (Pty) Limited (“First Defendant”) and Ride Away Mountain Biking And
    Cycling Tours CC (“Second Defendant”) (collectively referred to as “the
    Defendants”), as a result of The Plaintiff suffering significant damages due to the
    Defendants failure to obtain the required visas in relation to the Plaintiff’s and
    certain of the Plaintiff’s guests’ visit to Montenegro from the 05th to the 12th of
    August 2017 on his behalf.

    3. In order to determine the extent of the Defendants’ negligence and liability to the
    Plaintiff’s damages suffered as a result of the above, our offices require the
    following information and documentation from the Montenegrin Authorities, which
    we have been advised by the Serbian Embassy in Pretoria is in the control of the
    Montenegrin Ministry of Foreign Affairs or Home Affairs:

    3.1. Confirmation that only two visa applications were received in respect of
    each of the following individuals, respectively dated the 19th of June 2017
    (initial visa application) and the 3rd of August 2017 (re-submitted visa
    application):

    3.1.1. Mr. Justin Melvill McLeod


    Identity no: 671128 5275 08 3
    Passport no: M00094477
    Visa application ref: Vinka/K-237/2017;
    3.1.2. Mr. Colin Melvill McLeod
    Identity no: 441207 5030 08 3
    Passport no: A01381636
    Visa application ref: Vinka/K-236/2017.

    3.1.3. Mrs. Felicity Madeleine Yelva McLeod


    Identity no: 481126 0019 08 4
    Passport no: A01384289
    Visa application ref: Vinka/K-235/K-238/2017.

    (herein after referred to as “the Applicants”)

    3.2. Reasons for the refusal of the Applicants visa applications respectively,
    as it is our instructions that the Plaintiff had to resubmit the visa
    applications due to the initial applications not being adequately submitted;

    3.3. Copies of all the visa applications considered and received in respect of
    both the Applicants.

    4. As requested in your aforementioned correspondence, the relevant documents


    have been translated into Montenegrin and we herewith attach the following
    documents, together with copies in English, to accompany our request /
    application to the Montenegrin Authorities:

    4.1. Mr. Justin Melvill McLeod’s first Visa application dated the 19th of June
    2017 (Source document: Montenegrin and English);

    4.2. Mr. Justin Melvill McLeod’s second Visa application dated the 3rd of
    August 2017 (Source document: Montenegrin and English);

    4.3. Mr. Colin Melvill McLeod’s first Visa applicated dated the 19th of June 2017
    (Source document: Montenegrin and English);
    4.4. Mr. Colin Melvill McLeod’s second Visa application dated the 3rd of August
    2017 (Source document: Montenegrin and English);

    4.5. Booking confirmations received from Goolets LTD dated the 30th of May
    2017 for Mr. Justin Melvill McLeod, Mr. Colin Melvill McLeod and Mrs.
    Felicity Madeleine Yelva McLeod (Source document: English, Target
    document: Montenegrin);

    4.6. Invitation letters received from DM Yachting dated the 4th of August 2017
    for Mr. Justin Melvill McLeod, Mr. Colin Melvill McLeod and Mrs. Felicity
    Madeleine Yelva McLeod (Source document: Montenegrin, Target
    document: English);

    4.7. Letter of recommendation received from Serbian Embassy based in


    Pretoria, South Africa, dated the 27th of June 2017 (Source document:
    Serbian / Montenegrin, Target document: English).

    5. Pursuant to the above, we herewith once again request that your offices in
    accordance with the Hague Convention on the taking of Evidence Abroad in Civil
    and Commercial Matters, 18 March 1970 ("the Convention"), make available the
    evidence sought in paragraph 3 above.

    6. Our offices would appreciate if the requested documents and/or information


    serving as evidence could be made available as soon as possible in light of the
    legal proceedings having been set down for hearing on the 27th of May 2020, in
    the High Court of South Africa, Gauteng Local Division, Johannesburg.

    7. We trust you find the above in order and thank you for your assistance herein.

    Yours faithfully,

    ________________________
    Corien Potgieter / Albert J Arnold
    BRAND POTGIETER INCORPORATED

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