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"Q.11 what is the significance of the words "on completion of the signing of the agreement by both the sides'?
Ans. This was document draft which was to be signed by the defendant in Canada."

Q.15 Is it true that the draft of the first MOU was done by you without any involvement of the Defendant at that stage?

Vide email dated 6th January, 2005, the plaintiffs forwarded the draft MOU to the defendant. The said email reads thus :
"Dear Mr. Modi, I am sending you the draft MOU by email. Kindly review the attached document, fill in the spaces marked with [*], suggest any changes you might have. I have turned on the "track changes"
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app.564.15.doc Ans. This was document draft which was to be signed by the defendant in Canada."

Q.14. What is the significance of a reference to "the actual agreement to sell" in the last paragraph of the first page of exhibit P4?

Ans. This was because the agreement was first to be in an MOU which would be signed in Canada by the Defendant, the deposit amount would be kept in Bombay with a person that he might suggest and an agreement of transfer i.e. actual transfer of the flat would be in the second document."

Q.15 Is it true that the draft f the first MOU was done by you without any involvement of the Defendant at that stage?