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January 13, 2017 The Director NR3C-FIA National Police Foundation Building, 2nd Floor, Mauve Area, G-10/4, Islamabad. SUBJECT: COMPLAINT UNDER SECTION 18, 19, 20 & 24 OF THE PREVENTION OF THE ELECTRONIC CRIMES ACT, 2016. Respected Sir, 1.

I am Director, majority shareholder and CEO of Background Check (Private) Limited (hereinafter referred to as “the

Company�),

a

company

duly

incorporated and registered under the laws of Pakistan and having its registered office at 3rd Floor, GSA House, 19 Timber Pond, , East Wharf, Karachi. The company has it head office in Singapore where I am also residing to take care of Intenational buniess needs, bearing Singapore FIN ID G5379382M. The company is one of the leading and well estabilished risk managament service provider of the country, having many well reputed private and public sector clients world wide. 2.

That Syeda Mehvish Ali d/o Mumtaz Hussain Shah, currently working as a General Manager of the Company, was initially working as consultant from home in Islamabad. She was offered to work at the Karachi Office of the company vide Offer letter dated 30.09.2016 for a temporary period of three months. She accepted the offer after consultation with her parents and husband, and with their permission she moved to Karachi along her two children and mother. On 8 Nov 2016, Syeda Mehvish Ali was physically abused by her husband Syed Tayyab Ali Shah (who came to Karachi same day after having a fight between the husband and wife over the phone), and she felt threatened for her life. She left her apartment and came to my wife Mrs. Noreen Danish, who is Managing Director of the company and reporting manager of Syeda Mehvish Ali to seek refuge. Syed Mehvish Ali was then deliberately deserted by her husband in Karachi City which was an unknown city to her where she was struggling to settle down.


3.

Being an employee of the company and on humanitarian grounds, I and my wife Noreen Danish have been morally supporting Syeda Mehvish Ali since then to recover from the trauma of being abandoned by her family. It is for this reason, I, my family and other employees of the company have become target of cyber stalking, intimidation and harassment campaign by the family of Syeda Mehvish Ali, in particular her husband Syed Tayyab Ali Shah and her brother Saqib Mumtaz, who is a serving Lt. Col currently posted in Peshawar at FC Headquarters.

4.

That on 10.11.2016, Lt. Col Saqib Mumtaz sent a whatsapp message stating “Abhie tu party shoru howee hai” as a threat that his show begins now and he will do anything in his capacity to damage my reputation and business. He also threatened that a professional can track and record conversation in real time. On 10.12.2016, Lt. Col. Saqib Mumtaz located my location using his number (+92-34272-12121) and intimidated, harassed and threatened me by saying that run but you cannot hide from me. On 11.12.2016, he sent a whatsapp message that by turning off your cell you cannot hide your location. On 12.12.2016, Lt. Col. Saqib Mumtaz again sent me whatsapp messages from his number and abused and harassed me and leveled false, fabricated and baseless allegations on me. He again intimidated and harassed me on 13.12.2016 through whatsapp message from his above mentioned number saying he is aware of my location and will be sending someone to see me. On 31.12.2016, Lt.Col Saqib Mumtaz sent a whatsapp message sharing my traveling history of last three to four years and threatened me to run for my life. I changed my number due to the security concerns, however Lt.Col Saqib sent me details of my new number and sent a message “Say my salam to DIG Azad Khan, a very dear friend of mine. He is DIG South Nowadays”. This message shows clear threat and intention that he is using his contacts to harass me. 5.

That since then I have started to receive similar threatening and harassing messages from another number (+92-341-2699404). From the contents of the messages and the language being used, this number is used by Syed Tayyab Ali Shah. On December 22, 2016, a person delivered 15 letters by hand at the Company’s Office by addressing the employees with their name on the envelopes. I then received a whatsapp message from the number (+92-0341-2699404) that a Birthday Gift is


waiting for me in the office, which later turned out to be the letters written by Mumtaz Hussain Shah, father of Syeda Mehvish Ali where he raised baseless allegations on me. The letter was sent to the company’s employees with not only the intent to damage my reputation in the eyes of my employees but also to sabotage the operational activities of the company therefore incurring heavy losses. These letters were also emailed to the employee’s official email IDs containing the attachment of this letter and its contents. Furthermore, the employees also received the whatsapp images of the same letter along with the attachments from the number 0341-2699404 on their personal cell numbers. On 6.1.2017, same number was used to send a Whatsapp message that another TCS is ready to be dispatched. 6.

That above stated ongoing cyber stalking, harassment against me through whatsapp messages, SMS and emails to me and company’s employees by Syed Tayyab Ali Shah and Lt. Col Saqib Mumtaz has been carried out with intention to intimidate, coerce and damage my reputation and business. It is submitted that Lt.Col. Saqib Mumtaz is tracking my location by using illegal means and is continuously harassing me. The objective is very clear to induce fear in my family so that we withdraw Mehvish’s support. As stated above, Lt. Col. Saqib Mumtaz was previously using his personal number to send harassing messages to me. However, now a new unknown number is being used for this purpose. This new number is not on the name of Lt. Col. Saqib Mumtaz or Syed Tayyab Ali Shah, but the content of messages clearly show that these are from their side and continuation of earlier harassment campaign. Sir, it is another criminal offence to use a SIM which is not registered on the name of the user. The subject SIM is registered on the name of Mr. Muhammad Farhan, resident of Nusrat Bhutto Colony, Nazimabad, Karachi, bearing CNIC number 42101-6411262-9. Once inquired by me regarding this new number, Syed Tayyab Ali Shah or Lt. Col. Saqib Mumtaz openly claimed that this number is registered on their name and they have nothing to hide.

7.

It is submitted that above acts mount to offences against dignity of a natural person and cyber stalking under section 18, 19, 20 and 24 of the Prevention of Electronic Crimes Act, 2016, hence this complaint. It is submitted that the evidence of the


above illegal cyber harassment, intimidation and stalking is a matter of record and can be retrieved and provided by the complainant. It is, therefore, requested that my complaint may be lodged under Section 18, 19, 20 and 24 of the Prevention of Electronic Crimes Act, 2016, and action may be taken against Syed Tayyab Ali Shah, Lt. Col. Saqib Mumtaz and /or anyone else in accordance with law. For your ready reference I enclose herewith a detailed dossier to provide all the evidences in organized and factual manner.

_________________ Danish Farrukh Alvi Thanvi Flat no B2, Clifton Garden 1, Block 3, Clifton, Karachi NICOP: 42301-8308639-9 Singapore FIN ID G5379382M Phone Number: 0345-213092020

c.c. to: Singapore Honorary Consulate-General Karachi Ministry of Interior Complaint Cell General Head Quarters (GHQ - RWP) Khyber Pakhtunkhwa Chief Minister`s Complaint and Redressal Cell Office of the Core Commander Peshawar KPK Office of the Inspector General FC - KPK Khyber Pakhtunkhwa Provincial Ombudsman Office INTERPOL Global Complex for Innovation (IGCI), Singapore International Centre for the Prevention of Crime (ICPC), Canada


PREPARED BY LEGAL INTELLIGENCE UNIT -

BACKGROUND CHECK GROUP

ABOUT THIS DOSSIER Discovery is pre-trial investigation. It allows you to get either evidence itself, or information that will lead to getting the required evidence. In response to the letter written by Major (Retd) Mumtaz Hussain Shah dated 16th of December 2016 where he placed baseless allegations on Group CEO of Background Check Group, this dossier will serve as the official legal collection of evidence and will present the facts in more organized fashion to support any legal proceedings in any part of the world. 30 Cecil Street, #1908 Prudential Tower, Singapore 049712

SINGAPORE

ATLANTA

p. +65 31080343 f. +65 67228310

DUBAI

EVIDENCE DISCOVERY DOSSIER - JANUARY 13, 2017

KARACHI

info@backcheckgroup.com https://backcheckgroup.com

KUALA LUMPUR

TORANTO

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COMMITTED TO FIGHT AGAINST FRAUD & CORRUPTION

DISCLAIMER

The material contained in our response and any material or information disclosed during preparation of this dossier represent the public information keeping confidential pertaining to our methodologies and methods. all logos, products and brand names may be trademarks or registered trademarks of their respective owners and used in this document for demonstration purpose only. the owner of the logos may prohibit their use or may update or change their copyright policies and guidelines. the use of this document for any purpose whatsoever without prior approval of Background Check Pte Ltd is not authorized and considered illegal.

Dossier History If you edit the dossier, please add the date, your name, and a description of the change here. Rev. # Date of change Name of person making change Description of Change 1.0 27-DEC-16 John Leonard Initial evidence release. 2.0 29-Dec-16 Raiz Qassam Legal research 3.0 4.0

7th-Jan - 17 7th-Jan - 17

5.0

9th-Jan -17

Danish Thanvi

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Final review Submission to all relevant authorities Received acknowledgments

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TABLE OF CONTENTS DOSSIER HISTORY ...................................................................................................................................... 2 EXECUTIVE SUMMARY ........................................................................................................................ 5 RESPONSE TO THE ALLEGATIONS ................................................................................................... 5 ALLEGATION 1: THE ALLEGATION THAT JOB OFFER OF GENERAL MANAGER WAS A HOAX WITH AN INTENTION TO INTERFERE AND CREATE DISTURBANCE IN MEHVISH’S PERSONAL LIFE............................ 5 ALLEGATION 2: NOBODY WAS READY FOR HER RELOCATION AND ACCEPTANCE OF OFFER FOR THE POSITION OF GENERAL MANAGER AT BCG AND SHE CAME TO KARACHI WITHOUT THEIR PERMISSION. FOLLOWING ARE THE EVENTS HAPPENED DURING HER DECISION MAKING PROCESS FOR HER POSITION . 9 SCREENSHOT OF THE EMAIL WHERE MEHVISH IS ADDRESSING CONCERNS OF HER BROTHER LT. COL SAQIB MUMTAZ REGARDING HER RELOCATION TO KARACHI AND IN THE END A CLEAR CONSENT CAN BE SEEN BY SAQIB WHO IS SAYING GOOD LUCK TO MEHVISH FOR HER ENDEAVOR HOWEVER EVERYTHING WAS JEOPARDISED BY TAYYAB ALI SHAH WHEN MEHVISH WAS ATTACKED BY HIM AND THEN SHE WAS ABANDONED ONE MONTH BEFORE THE COMPLETION OF THAT PROJECT CAUSING LOSSES FOR THE COMPANY .................................................................................................................................. 11 PROOF OF DUA AND FAHEEL’S SCHOOL TRANSFER FROM CITY SCHOOL DHA 2 RAWALPINDI TO CITY SCHOOL PAF CHAPTER KARACHI THAT SHOWS THIS RELOCATION DECISION WAS NOT DONE OVERNIGHT NEITHER IT WAS WITHOUT ANY CONSENT FROM THE FAMILY ............................................. 14 ALLEGATION 3: TAYYAB CAME TO KARACHI ON NOVEMBER 8, 2007 DUE TO EMERGENCY MEDICAL CONDITION (MIGRAINE ATTACK) OF MEHVISH ON NOVEMBER 7, 2016. ................................................ 15 ALLEGATION 4: THE FIGHT BETWEEN HUSBAND AND WIFE IN THE PRESENCE OF HER MOTHER AND SHE LEFT THE HOUSE IN HURRY LEAVING THE CHILDREN CRYING BEHIND ................................................... 16 ALLEGATION 5: THEY COME TO KNOW ABOUT THAT MEHVISH IS PRESENT AT NORREN’S PLACE BY DANISH PHONE AND IT APPEARS THAT SHE HAS GONE INTO DANISH’S CUSTODY. WHERE DANISH USED INDECENT LANGUAGE AND THREATENED TAYYAB TO BREAK HIS LEGS AND TAKE HIS CHILDREN AWAY. HE ALSO ORDERED HIM TO GET OUT FROM THE COMPANY PROVIDED RESIDENCE. ........................... 17 ALLEGATION 6: TO PROTECT THE CHILDREN FROM DANISH, MEHVISH’S MOTHER AND HER HUSBAND TAYYAB SHIFTED TO MALIR CANTT ALONG WITH HER CHILDREN. THEY WENT BACK TO PESHAWAR ON NOVEMBER 10, 2016. .............................................................................................................................. 18 ALLEGATION 7: WHATSAPP CONVERSATION BETWEEN DANISH AND MEHVISH, USE OF DRUGS & SPY SOFTWARE’S WHICH COMES UNDER CYBER CRIME ................................................................................. 19 ALLEGATION 8: HE REMAINS ABSENT FROM HOME FOR DAYS AND LIVING WITH MEHVISH AT HER RESIDENCY. THEY WERE UNABLE TO GET IN CONTACT WITH NOREEN AND DANISH’S MOTHER BECAUSE OF DANISH’S FORCEFULLY STOPPING THE COMMUNICATION. ................................................................ 25 ALLEGATION 9: MOTHER OF SMALL KIDS ABANDONED THEM................................................................ 26 ALLEGATION 10: DANISH AND BCG ARE IN THE EYES OF THE LAW ENFORCEMENT AND CAN BE HELD ANY TIME AND THEIR EMPLOYEES WILL ALSO GET INVOLVED UNINTENTIONALLY IN THEIR CRIMES. THE INVESTIGATION IS ALREADY STARTED FROM YOUR COLLEAGUES. ......................................................... 27 ALLEGATION 11: BCG’S BOAT IS ABOUT TO SINK. THE EMPLOYEES ARE WARNED SO THAT THEY DO NOT GET INTO THIS MESS UNINTENTIONALLY AND MAKE THEIR FAMILY LIVES HELL. ........................... 28

MALICIOUS CONTENTS OF THE LETTER BEING USED FOR BLACKMALING .................. 28 SELFIE OF DANISH & MEHVISH ............................................................................................................... 28 PREVENTION OF ELECTRONIC CRIMES ACT, 2016 .................................................................................. 28 HOW TO MAKE A FAKE PICTURE WITH FAMOUS PEOPLE?................................................................... 29 SELFIE OF DANISH THANVI IN WASHROOM ............................................................................................ 29 CIRCULATION OF THE LETTER AND BLACKMAILING ........................................................... 29 HARASSMENT BY THE POLICE OF BCG EMPLOYEES AND MANAGEMENT ..................... 32 Screenshots of SMS sent from Noreen Danish to Danish Thanvi informing about the harassment by Police and other agencies.................................................................................................................... 32

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Screenshots of email received by danish thanvi from head of technology who is informing him about the harassment of one of the employee khizer by Police. .................................................................... 33 MILITARY INTELLIGENCE, KEMARI POLICE & SPECIAL BRANCH .................................... 33 CYBER HARRASMENT AND SECURITY THREATS TO GROUP CEO BCG DANISH THANVI .................................................................................................................................................... 34 TRAVEL HISTORY OF DANISH THANVI ................................................................................................... 37 CONSPIRACY TO ABDUCT DANISH THANVI AND TORTURE HIM PHYSICALLY ............. 37 TRANSCRIPTION OF THE CALL ................................................................................................................. 37 CALL AUDIO: ........................................................................................................................................... 38 IDENTITY THEFT AND CYBER HARRASMENT ............................................................................ 39 FACEBOOK TECHNICAL SUPPORT WAS CONTACTED BY MEHVISH AS SHOWN IN THE SCREENSHOT BELOW TO RECOVER OF HER FACEBOOK ACCOUNT ................................................................................. 41 MEHVISH REQUEST TO GMAIL SUPPORT FOR RECOVERY OF HER EMAIL ID: S.MEHVISH.ALI@GMAIL.COM . 42 LEGAL REPERCUSSION OF THE EVENTS HAPPENING SINCE NOVEMBER 8.2016 ........... 43 CLAIM FOR DEFAMATION DAMAGE ............................................................................................. 43 ANNEXURE 1: LETTER OF MUMTAZ HUSSAIN SHAH (FATHER OF MEHVISH) ................ 44 ANNEXURE 2: LIST OF CURRENT & EX EMPLOYEES WHO RECEIVED THE LETTER ... 46 LIST OF CURRENT EMPLOYEES ................................................................................................................ 46 LIST OF EX- EMPLOYEES .......................................................................................................................... 47 ANNEXURE 3: STOLEN CELL PHONE REPORT TO PTA, CPLC AND CLIFTON POLICE STATION .................................................................................................................................................. 52 COPY OF APPLICATION SUBMITTED BY MEHVIH’S ALI TO THE BOAT BASIN POLICE TO REPORT THE INCIDENT AND STOLEN COMPANY PROPERTY .......................................................................................... 52 COPY OF THE APPLICATION TO THE CITIZEN POLICE LIAISON COMMITTEE (CPLC) ............................. 54 SPECIFICATION OF MEHVISH’S CELL PHONE ............................................................................................ 55 ANNEXURE 4: DESCRIPTION OF MEHVISH’S STOLEN LAPTOP ....................................................... 56 ANNEXURE 4: LAPTOP RECEIPT...................................................................................................... 63 ANNEXURE 5: HOW TO MAKE A FAKE PICTURE WITH FAMOUS PEOPLE TO IMPRESS YOUR FRIENDS AND FAMILY............................................................................................................................. 64 COMBINING TWO PHOTOS WITH A PHOTO EDITOR ................................................................................. 64

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EXECUTIVE SUMMARY This dossier was prepared by the legal team of Background Check Pte Ltd in response to the letter which was written by father of Mehvish Ali, Mumtaz Hussain Shah on 16th of December. The letter was first sent to the Karachi office of Background Check Pvt. Ltd by hand on the 22nd of December to mark it as a Birthday gift for group CEO, Danish Thanvi (as claimed in one of the whatsapp threats). The letter was sent to the random employees both current and former, received this letter delivered by hand or via their office emails and personal what's app numbers. The letter was written in maligning and foul language without any evidence to support the baseless and forged allegations fabricated for the purpose of creating a serious damage to the business and its leadership by provocation of employees’ emotion against the company and its CEO. The damage has been made with ill intention to take revenge because of support provided to Mehvish when she was left deserted by her family in an unknown city. This dossier provides all the facts and figures to bring the truth into light and address the baseless allegations whereas use this dossier will be presented to court of law where applicable.

RESPONSE TO THE ALLEGATIONS

ALLEGATION 1: THE ALLEGATION THAT JOB OFFER OF GENERAL MANAGER WAS A HOAX WITH AN INTENTION TO INTERFERE AND CREATE DISTURBANCE IN MEHVISH’S PERSONAL LIFE The responses to the allegations raised by Mehvish’s father, following are the evidences in the light of actual facts and figures. Mehvish was involved in company’s business development for almost 10 months when she was offered to work on an HR project to bring a new and more vibrant policy framework structure for the company’s smooth operations and steady growth. As she has got the understanding of the business in past 10 months and having over 12 years of experience in HR, trainings and career development, it was making a perfect sense to select her for this short-term project running from Karachi office instead of hiring a local consultant for the same. The company set a rather rigid timeline of 3 months just to give confidence and sense of comfort to her family that her project was supposed to be completed by end of December 2016 when she would have been going back to Islamabad to implement the same framework to establish BCG operations and start business development activities in North region. Although she got permission from her family for this temporary 3 months’ relocation, the agreement was breeched in just one EVIDENCE DISCOVERY DOSSIER - JANUARY 13, 2017

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and a half month and due to unfavorable circumstance being created by her family members, Mehvish was asked to resign from the post as GM. We have listed the following events occurred during the one-month decision making process before any acceptance of job offer was also evident that she has got the consent of her family before making any move to accept work from Karachi office. a) Mehvish along with her mother and 2 kids, Dua and Faheel, arrived in Karachi on Sunday 16th October. Their E-ticket is attached below. Her kids got transfer from City School DHA 2 Islamabad to City School PAF Chapter Karachi. The school fees was transferred by her husband Tayyab Ali Shah

b) Background Check Group Pvt. Ltd. made an offer to Mehvish for the position of General Manager (reporting to MD Norren Danish) for three months with relocation to Karachi from October to December 2016. She was required to go back to Islamabad in January 2017 to establish Islamabad office of Back Check EVIDENCE DISCOVERY DOSSIER - JANUARY 13, 2017

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group with the name of Risk Discovered (Risk Discovered is a registered trade mark of Background Check Pakistan Ltd ) –

c) Risk Discovered Pvt Ltd. was incorporated in Islamabad on September 26, 2016. Certificate of incorporation attached with the shareholding structure of the company: Danish 50%, Mehvish 40% and Norren 10%. Mehvish was also appointed as CEO to start the operations of Islamabad Company from January 2017.

Certificate of Incorporation of Risk Discovered Pvt. Ltd.

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Risk Discovered Pvt. Ltd. Directors & Shareholders

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ALLEGATION 2: NOBODY WAS READY FOR HER RELOCATION AND ACCEPTANCE OF OFFER FOR THE POSITION OF GENERAL MANAGER AT BCG AND SHE CAME TO KARACHI WITHOUT THEIR PERMISSION. FOLLOWING ARE THE EVENTS HAPPENED DURI NG HER DECISION MAKI NG PROCESS FOR HER POSITION

a) The job offer was made on September 15, 2016 during the visit of her husband to Karachi office, when her husband Syed Tayyab Ali Shah and her children Syed Muhammad Faheel Ali (aged 9.5 years) and Dua e Fatima (aged 4.5 years) met Managing Director Norren Danish to discuss the relocation matters. Norren presented the offer letter to Mehvish and her husband to decide about the relocation before September 30, 2016. Offer letter attached

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b)

After going back to Islamabad, with mutual consultation of her husband and parents, Mehvish accepted the offer from October 1, 2016 and planned to join the Karachi office full time from October 17, 2016. She also consulted her brother Lt Col Saqib Mumtaz who initially had reservation on her relocation, however Mehvish addressed his concerns one by one and got his consent too for her relocation.

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SCREENSHOT OF THE EM AIL WHERE MEHVISH IS ADDRESSING CONCERNS OF HER BROTHER LT. COL SAQIB MUMTAZ REGARDI NG HER RELOCATION TO KARACHI AND IN THE END A CLE AR CONSENT CAN BE SEEN BY SAQIB WHO IS SAYING GOOD LUCK TO MEHVISH FOR HER ENDE AVOR HOWEVER EVERYTHING WAS JEOPARDISED BY TAYY AB ALI SHAH WHEN MEHVISH W AS ATTACKED BY HIM AND THEN SHE WAS AB ANDONED ONE MONTH BEFORE THE COMPLETION OF TH AT PROJECT CAUSING LOSSES FOR THE COMPANY

c)

Although she got permission from her husband to relocate to Karachi office along with her kids and mother, her husband was unable to join her due to his ongoing business activities in Islamabad. It was decided that he will be joining her later.

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d)

On October 13, 2016, Mehvish went back to Islamabad to bring her kids along with her mother to stay in Karachi apartment (Cornish Residency, Block C, Flat 6c1, Clifton) which was rented by Mehvish on her name by the help of company admin staff member Kazim Ali. Kazim Ali was officially involved in this task to support Mehvish to find a suitable residence. The rented apartment was of three bedrooms at 2000 sq ft, which was taken by keeping in view her family will be staying with her and sufficient enough to accommodate her family. Tenancy agreement is attached below.

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Tenancy Agreement of Syeda Mehvish Ali for her Apartment e)

On October 16, 2016, Mehvish arrived in Karachi with her mother and Faheel & Dua (her children) then she started the transfer process from City School DHA Campus Islamabad to City School PAF Chapter Karachi. The transfer was completed on October 25, 2016 and the children joined the school from October 26, 2016. Tuition Fee Challan

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PROOF OF DUA AND FAHEEL’S SCHOOL TRANSFER FROM CITY SCHOOL DHA 2 RAWALPINDI TO CITY SCHOOL PAF CHAPTER KARACHI THAT SHOWS THIS RELOCATION DECISION WAS NOT DONE OVERNIGHT NEITHER IT WAS WITHOUT ANY CONSENT FROM THE FAMILY

f)

g)

The transfer of children school also took place with the permission of her husband Tayyab, where he transferred Fees of both children to her account. Account statement can be furnished. Her car was also transported to Karachi with the help of her father and husband. Below are the images of the cargo receipt of the car shipped by Mumtaz Hussain Shah

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ALLEGATION 3: TAYY AB CAME TO KARACHI ON NOVEMBER 8, 2007 DUE TO EMERGENCY MEDICAL CONDITION (M IGRAINE ATTACK) OF M EHVISH ON NOVEMBER 7, 2016.

a) From credible sources Mehvish came to know that her husband was involved in some illegal activities where the FIR was about be launched on him whereas she was unaware of these activities. She and her mother had a quarrel on that day over this matter. Due to high stress Mehvish was admitted in the emergency same day in the evening for the treatment of migraine. Norren Danish accompanied her and paid the bills for her two hour stay at South City Hospital. (Bills can be furnished). b) On November 8, 2016, Mehvish inquired the matter from her husband (of his illegal activities) due to which they had a fight over the telephone. After that her husband rushed to Karachi which was never brought to her knowledge. The call was recorded by Mehvish and can be presented as an evidence.

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ALLEGATION 4: THE FIGHT BETWEEN HUSBAND AND WIFE IN THE PRESENCE OF HER MOTHER AND SHE LEFT THE HOUSE IN HURRY LEAVING THE CHILDREN CRYING BEHIND a) On November 8, 2016, Mehvish was unaware that her husband was hiding in the washroom when she arrived home after office around 6:30pm. Her husband came out of the washroom in aggressive manner which was a shock to Mehvish who was unaware of his presence. Mehvish tried to protect herself from his aggression due to which she got bruises on her both hands (Pictures attached). The pictures were taken on November 11, 2016

b) During this time Tayyab snatched the mobile phone from her hands and went out of apartment to hide it somewhere. When Mehvish followed him out of the apartment and saw his increasing aggression, she felt her life being threatened and decided to leave the apartment to go to MD Norren home which was just 1 km away from Mehvish’s residence. c) When she got to Norren home and informed her about the current situation, she was requested her to help in the situation so she can get back to her children safely. EVIDENCE DISCOVERY DOSSIER - JANUARY 13, 2017

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ALLEGATION 5: THEY COME TO KNOW ABOUT THAT MEHVISH IS PRESENT AT NORREN’S PLACE BY DANISH PHONE AND IT APPEARS THAT SHE HAS GONE INTO DANISH’S CUSTODY. WHERE DANISH USED INDECENT LANGUAGE AND THREATENED TAYYAB TO BREAK HIS LEGS AND TAKE HIS CHILDREN AWAY. HE ALSO ORDERED HIM TO GET OUT FROM THE COMPANY PROVIDED RESIDENCE. a) Danish Thanvi being an employer (majority shareholder BCG) and husband of Norren Danish was present at home, attended the call of Tayyab who wanted to inquire about Mehvish’s whereabouts. Danish informed him that she was at his place. He invited Tayyab to come to his place to sort this matter out. b) After the call Danish sent the same request Tayyab via whatsapp messages and also SMS the same matter for which the screenshots of messages are attached below. And it can be seen clearly there was no indecent language being used. Due to the aggression of Tayyab on BCG employee, Danish being the CEO of the Group explained the situation from company’s point of view and requested Tayyab to come to his place to resolve this matter amicably. c) At 8:17pm Danish sent Tayyab his home address and asked him to come ASAP to resolve this matter. To which Tayyab replied on 8:20pm that he was coming. But waiting for couple of hours, Mehvish tried to contact Tayyab on his cell number, their cells were turned off. d) Danish mentioned to Tayyab that Mehvish is being harassed and forced to leave the apartment which is a criminal offence. Screenshots of the conversation is attached below.

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ALLEGATION 6: TO PROTECT THE CHILDREN FROM DANISH, MEHVISH’S MOTHER AND HER HUSBAND TAYYAB SHIFTED TO MALIR CANTT ALONG WITH HER CHILDREN. THEY WENT BACK TO PESHAWAR ON NOVEMBER 10, 2016. a) Mehvish was trying to contact her husband and her mother, but their cell numbers were turned off. On which the concern came to her mind that what happened to her apartment. b) Mehvish called the Owner who was also the neighbor living on the same floor and asked him to check the current situation at her apartment. After checking the owner informed Mehvish that no one is there and her apartment is locked from outside. c) As Mehvish got no keys to go back to her apartment so she had to stay the night at Norren’s apartment. During this time they kept on trying to contact Tayyab and her mother on their cell phone which were off the network as Mehvish was worried about the children wellbeing. d) On November 9, 2016, Mehvish first went to apartment to check. She had to replace the lock and checked the current situation of the apartment. From there she came to know that her belongings were missing that includes her original educational documents, ATM Card, Cheque Book, Original CNIC, Original documents of car, hand bag, Insurance card along with currency Rs. 13,000/-. EVIDENCE DISCOVERY DOSSIER - JANUARY 13, 2017

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e) Now Mehvish looked for her car which was missing and she came to know that her husband took it with him. The car was Japanese Alto, Model 2011 worth Rs. 1 million registered on her name. f) Through some reliable source Mehvish came to know that her mother and her husband were staying in some Army Mess located near Avari Hotel. Mehvish along with Norren went to first Services Mess to find her mother and husband. From the services mess they came to know that they did not stay here. The staff suggested them to check at Balouch Mess. g) When they went to Balouch Mess, they were told that they were here last night and they left the Mess early in the morning. Mehvish still tried to contact them on their cell phones which were still turned off. h) After unable to find them, Mehvish along with Norren went to CPLC where they explained the situation to Ms. Quratul-Ain and given a written application (Ref: 3537/NOV) in anticipation that CPLC will provide support to locate her family. i) In the evening Danish messaged Tayyab that Mehvish tried to reach you all day so kindly get in contact with her to resolve this matter.

ALLEGATION 7: WHATSAPP CONVERSATION BETWEEN DANISH AND MEHVISH, USE OF DRUGS & SPY SOFTWARE’S WHICH COMES UNDER CYBER CRIME a) The mobile phone and laptop that was in Mehvish possession was the property of Background Check Pvt. Ltd., which is now being reported to Police as a stolen property. It is now turning out to be the fabricated evidence against the CEO and General Manager of Background Check Group to damage the reputation of the company and to blackmail the owners. The 58 pages whatsapp conversation which is mentioned here is taken out from that stolen property of Background Check Pvt. Ltd after 38 days of the incident is nothing more than a hoax to support their false claim. EVIDENCE DISCOVERY DOSSIER - JANUARY 13, 2017

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b) We have tried to search Malu and Tanzania Drugs on google and did not find any reference associated with any sort of drug. If required the CEO and GM of BCG can go through drug screening test from any reputable hospital.

Malu Drug Google Results

Tanzania Drug Google Results c) We are unable to find any such evidence where any employee of BCG or their relatives are being monitored by any spy software. While searching on google we did not find any software with these names. Moreover, we come to know that this software cannot be installed remotely and required possession of the physical device for 15 to 20 minutes minimum.

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Ihover google results

Android Spyware Google Results

d) During visit of Tayyab on September 15, 2016, Danish was travelling to Gwader and was not able to meet him personally. Physical Possession of his device was not possible in these circumstances. e) There was no spy software which was installed on Mehvish’s cell. Auto voice recorder app was installed by herself that records the surrounding sound when crossed certain threshold level and then upload the recorded files on cloud server.

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f)

As there is no software installed in any cell phone therefore there is no cybercrime offense. However, in the recent events when brother of Mehvish, Saqib Mumtaz who is a serving Lt. Col currently posted in Peshawar at FC Headquarters, illegally tracked the locations of the Group CEO Danish Thanvi and threatened his security. The communication with Saqib on whatsapp and the threatening messages are evident below

Screenshots are attached below:

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ALLEGATION 8: HE REMAINS ABSENT FROM HOME FOR DAYS AND LIVING WITH MEHVISH AT HER RESIDENCY. THEY WERE UNABLE TO GET IN CONTACT WITH NOREEN AND DANISH’S MOTHER BECAUSE OF DANISH’S FORCEFULLY STOPPING THE COMMUNICATION. a) Danish has business engagements in Gwader due to which he has to travel frequently from time to time and it started in early August where he was working with some Singaporean company to facilitate them in their Gwader Project. Therefore these trips start way before the events happened since November 8, 2016. On December 12, 2016, Danish shared his current location of Gwader through whatsapp with Lt. Col. Saqib on his similar allegation that Danish is spending time with Mehvish on her apartment (attachments below of Gwader email & location). b) On December 12, 2016, Mehvish’s mother called at Danish’s residence and spoke to his mother and his wife for nearly half an hour. If there was any restriction from Danish to stop the communication, then this call would not have taken place.

Communication happening early August 2016 Similar allegation put by Saqib, where on his Gwader Engagements Danish shared his current location of Gwader c)

The Role was Kazim Ali (Admin Officer) was to facilitate Mehvish in relocation and getting the apartment for few months as Karachi was new city for her, therefore Kazim helped her in getting the administrative tasks done so that she can focus on her official assignement for which she was relocated from one city to another city. Kazim role ended when all of the relocation tasks were completed including the transfer of Mehvish’s Children school. He is no more involved in any task related to Mehvish.

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ALLEGATION 9: MOTHER OF SMALL KIDS ABANDONED THEM a) Mehvish was left deserted by Tayyab and her mother on November 8, 2016. All of her belongings were missing that includes her original educational documents, ATM Card, Cheque Book, Original CNIC, Car and its original documents of car, hand bag, Insurance card along with currency Rs. 13,000/-. She had no money to fulfill the basic requirements for which Noreen lent her Rs. 10,000/b) After knowing that her husband and her mother left the apartment with kids. She tried to contact them but their mobile numbers were off. In this desperation she went to CPLC to get help in locating the children through the mobile numbers of Tayyab (0333-5207750 and 0340-5599554) and her mother (0333-5899554). c) After few days Col Sher, CO 4 Sindh, contacted Mehvish to return her hand bag. A communication between Col Sher and Mehvish established where he acted as mediator on behalf of her father (as told by Col Sher to Mehvish) between Mehvish and her family to resolve the matter. After long discussion, Mehvish was assured that she will be returned all her belongings including her car. In exchange she has to give undertaking that she will not claim her kids through any court. Mehvish declined that offer to give up her legal right over her children. d) Lt. Col Saqib visited Karachi during his official visit to Ideas Conference during December 22-26, 2016. He remained in the city but he did not contact Mehvish to check her wellbeing. Mehvish was not even informed about Saqib’s presence in the city. She was informed by Col Sher on November 29, 2016 that Saqib was in Karachi, which clearly shows that her family abandoned her.

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e) The children were admitted in The City School PAF Chapter. Mehvish’s family left in so hurry that they did not even inform the School Administration regarding the absence of children from the school. The school administration later contacted Mehvish to check the wellbeing of the children. f) Therefore, at no point Mehvish abandoned her kids or family, instead she was forced to abandon them.

ALLEGATION 10: DANISH AND BCG ARE IN THE EYES OF THE LAW ENFORCEMENT AND CAN BE HELD ANY TIME AND THEIR EMPLOYEES WILL ALSO GET INVOLVED UNINTENTIONALLY IN THEIR CRIMES. THE INVESTIGATION IS ALREADY STARTED FROM YOUR COLLEAGUES. a) In the light of the evidence presented in this dossier here proves that most of the allegations presented in the letter are fabricated and presented without any facts. And the malicious intent here is to damage the reputation of BCG Company and Management by spreading this fear and creating mistrust among the employees of BCG to paralyze the company’s operations. All this is in reaction to company and its management’s support (MD Norren Danish & CEO Danish Thanvi) to Mehvish in the time she was deserted by her family and their support was enabling her to survive in the time of crisis. b) According to Prevention of Electronic Crimes Act, 2016, any information shared publically which is false to intimidate or harm the reputation of a person is punishable offence of three years with a fine of Rs. 1 million.

Selective clause from Prevention of Electronic Crimes Act, 2016 c) The employees are threatened and harassed with this present situation that their colleagues are being investigated by the law enforcement agencies, therefore they can also get involved in this situation.

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ALLEGATION 11: BCG’S BOAT IS ABOUT TO SI NK. THE EMPLOYEES ARE WARNED SO THAT THEY DO NOT GET INTO THIS MESS UNINTENTIONALLY AND MAKE THEIR FAMILY LIVES HELL. a) This statement is written with an intent to make a serious damage to the company by claiming that the business is about to be collapsed which is presented without any substantial evidence. Such statement is creating a situation in a company causing despair and distress within the employees which will result in adversely affecting the operational activities of the company thus sabotaging the business activities.

MALICIOUS CONTENTS OF THE LETTER BEING USED FOR BLACKMALING The letter along with the allegation carried the attachments to strengthen their claims. Following were the attachments along with the letter: 1. Mehvish CNIC 2. Family Photograph of Mehvish Family 3. Picture of Danish and Mehvish 4. Selfie of Danish in washroom

SELFIE OF DANISH & MEHVISH 1. The Selfie of Danish and Mehvish which was presented in the letter as they were spending some time together while the picture was taken. There is high probability that this picture was fabricated as the faces were too zoomed and there was no body part visible through which a person can be identified. 2. It also come under the Prevention of Electronic Crimes Act, 2016, that a person face is superimposed over some sexually explicit image and circulated publically to take revenge, create hatred or to blackmail will be punishable offence of five years with the fine of Rs. 5 million. 3. The intent of the Mehvish’s family is very clear from the content of this letter that they want to take revenge from BCG for supporting Mehvish when her family left her deserted. They also want to cultivate hatred in the employees against the management.

PREVENTION OF ELECTRONIC CRIMES ACT, 2016

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Fabricated Image of Danish & Mehvish

HOW TO MAKE A FAKE PICTURE WITH FAMOUS PEOPLE? Here is an interesting article about how easy is it to fake a photo by combining two different photographs. Maybe you want what looks like a picture of yourself and a celebrity together as a joke, or you're out to impress some people. Whatever the reason, modern technology can help you get the snapshot you want.

Read full article in Annexure 5

SELFIE OF DANISH THANVI IN WASHROOM The picture was taken by Danish by the same cell phone which was later given to Mehvish for her official use after formatting the contents of the phone. The image proved that some sort of illegal forensic software was being used to recover the deleted data. This objectionable picture was taken by Danish himself when he was alone and it was circulated with ill intent to damage his reputation publically.

CIRCULATION OF THE L ETTER AND BLACKMAILING This letter was circulated by the following mediums: 1. Hand Delivered the letter at BCG Office 2. Emailing the letter with the attachments to the employee official IDs 3. Sending whatsapp images to almost 300 of BCG current and former employees on their personal cell numbers – this data was acquired by illegal means – refer to Annx 2 a) On December 22, 2016, a person delivered 15 letters by hand at BCG Office addressed to the employees. Group CEO also received a whatsapp message from unknown number (03412699404) that a Birthday Gift is waiting for him in the office, which later turned out to be this letter, sent to damage the reputation of BCG Management in the eyes of their employees. The messages exchanged are presented in the screenshots given below:

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The letter was sent to almost 300 employees (Current & former) by hand, through email and also by the whatsapp message using the number 0341-2699404. The name and designation of the employees is mentioned in the Annexure 2. On December 30, 2016 – same number was used to sent the threats of another to be dispatched to the employees with the new stuff on DVD. The harassment continued with this message that even if traveling abroad, CEO Danish Thanvi will be held by the authorities. This message shows clear intent of misusing the resources by Lt. Col Saqib Mumtaz and Syed Tayyab Ali Shah, who are using this number.

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On January 5, 2017 again the threat was sent by the same number to dispatch a TCS, which was repeated again on January 11, 2017. The latest message was to send the TCS to all current and ex employees on their home addresses.

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HARASSMENT BY THE POLICE OF BCG EMPLOYEES AND MANAGEMENT After the letter and whatsapp images, the police started to contact the employees to come to Police Station and record their statement against the BCG Management particularly Group CEO Danish and GM Mehvish. In this regard one of the employee Mr. Khizer, who is a Verification Officer and working with BCG for more than 3 years, was called on his cell and was asked to come to Shah Faisal Police Station for recording the statement. This act is clear harassment by the local law enforcing agency which is supporting Saqib’s family in their malicious intent to damage the reputation of BCG Company and Management.

SCREENSHOTS OF SMS SENT FROM NOREEN DANISH TO DANISH THANVI INFORMING ABOUT THE HARASSMENT BY POLICE AND OTHER AGENCIES.

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SCREENSHOTS OF EMAIL RECEIVED BY DANISH THANVI FROM HEAD OF TECHNOLOGY WHO IS INFORMING HIM ABOUT THE HARASSMENT OF ONE OF THE EMPLOYEE KHIZER BY POLICE.

MILITARY INTELLIGENCE, KEMARI POLICE & SPECIAL BRANCH a) On December 29, 2016 Col Sher informed Mehvish that Lt. Col Saqib visited Karachi to attend the Ideas Conference during the Dec 22-26, 2016. Just after the Ideas exhibition, strange events started happening at BCG Karachi Office. December 23, 2016, a person came who claimed to be from Military Intelligence and asked for employee details. The person did not carry any Identification to prove that he belongs to Military Intelligence neither the person was able to produce any official intimation or letter where it could be established that military intelligence sent their representative to BCG officially. He was provided with the General Marketing material of the company and personal details of employees as asked by the person, was not shared due to confidential nature of the information. Sharing such information could breach the privacy of the BCG employees and could become a security threat for the BCG employees. Following table shows the details of various visits and calls by unverified Military Intelligence people to harass the employees and management of BCG

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Sr.

Date

Person Name

Office Visit Time

Remarks

1

23-Nov16

Rehan Ali

12:45 PM

Asking to hand over the details of company and its employees without any letter.

2

24-Nov16

Mohd. Iqbal

10:39 AM

Asking to hand over the details of company and its employees without any letter. Company documents issued to him for proof of company existence.

3

24-Nov16

Mr. Zubair

3:10 PM

Called received from Mr. Zubair, instructed to inform Danish Sb to visit Military Intelligence office at 3 Talwar. Tel# 99201449

4

24-Nov16

Mr. Zeeshan

3:25 PM

We called back Mr. Zubair where we get in touch with Mr. Zeeshan and informed him that Mr. Danish have left the office premises and we are unable to provide him the details to visit M.I office.

5

24-Nov16

Mr. Ali

3:45 PM

Again we called this number to have the exact address of the office, Mr. Ali pick up the phone and mentioned that the office is situated at teen talwar, Bath Island near Hilal e Hamar, also said to come near this place and call on above mentioned number so exact address can be guided.

After MI People, on November 28, 2016, Kemari Police started to harass the office staff on inquiring about Group CEO Danish whereabouts. SHO Kemari threatened the staff member Kazim that he will be picked up along with the other staff members, if he does not share Group CEO Danish’s location with them. At that point Managing Director Norren Danish was in the office and went through a severe mental torture as the Police was on the doorstep of BCG Karachi Office and harassing the staff. Two individuals who claimed to be from Special Branch arrived at Group CEO Danish’s residence and asking about Danish’s whereabouts. Again there was no identity produced by those individuals.

CYBER HARRASMENT AND SECURITY THREATS TO GROUP CEO BCG DANISH THANVI There is ongoing harassment against Group CEO Danish Thanvi by WhatsApp messages and SMS by Tayyab and Lt. Col. Saqib. He is tracking Danish Thanvi’s location by using illegals means and harassing him. The objective is very clear to induce fear in Danish Thanvi and his family so that they withdraw Mehvish’s support. Lt. Col Saqib was previously using his personal number to send harassing messages to Danish Thanvi. However a new unknown number (0341-2699404) is now being used. This new number is not on the name of Saqib or Tayyab, but the messages clearly show that it was sent from their side. This SIM is not registered on the name of the Lt. Col Saqib or Tayyab and it is also established that it is not the third person as it seems to be. This SIM is registered on the name of Mr. Muhammad Farhan, resident of Nusrat Bhutto Colony, Nazimabad, and Karachi bearing CNIC number 421016411262-9. However it is being used by Tayyab to send harassing messages to Danish Thanvi. EVIDENCE DISCOVERY DOSSIER - JANUARY 13, 2017

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The screenshots shared above shows very clear cyber harassment and security threats to Group CEO Danish Thanvi. The messages also shared the the intent to demage his reputation and hampering the business operations by sending fabricated material and demoralizing the employees.

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TRAVEL HISTORY OF DANISH THANVI On 31.12.2016, Lt .Col Saqib Mumtaz sent a whatsapp message sharing the screenshot of Danish Thanvi’s traveling history of last three to four years and threatened him to run for his life. If the travel history is obtained by using the official channels of Lt. Col Saqib Mumtaz which clearly shows the misuse of Public resources by an officer of Pakistan Army.

CONSPIRACY TO ABDUCT DANISH THANVI AND TORTURE HIM PHYSICALLY There is a conspiracy to abduct Danish Thanvi and beat him to create a hostile pressure on the company and his family which will lead to paralyzing of his business and personal life and ultimately the perpetrators will get their ill-will achieved. This conspiracy came into light when Tayyab and Lt. Col. Saqib were exchanging a telephone call made on November 11, 2016 at 1304hrs, when coincidently Tayyab’s voice was recorded by an app (Auto Call Recorder) installed in the stolen cell phone of Mehvish (company property allocated to her but was snatched and robbed by Tayyab on 8th of November 2016) which was placed near Tayyab. In this call Tayyab informed Lt. Col Saqib that he has some contacts in Military Intelligence Karachi who can help in getting Danish abducted.

TRANSCRIPTION OF THE CALL This call was made on November 11, 2016 between Tayyab and Lt. Col. Saqib at 1304hrs which was recorded by the app Auto Call Recorder in Mehvish’s cell phone held in Tayyab’s custody. The app automatically upload the data on the cloud which a user can retrieve by signing in to the online account. Transcript (Voice of Tayyab) I have changed her (Mehvish’s) Facebook password with the mobile app of cell phone. Her cell phone is rooted which is used for modeted games and apps. She has invested in Meezan Bank by selling her gold where she took one policy which is on the name of both of us.

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In case if anything happens to her then I will be the next of kin. I don't know what will happen in case of Khula. Probably in that case I will be eligible to claim that investment. I don't want money. I just want that they should have less funds so that they suffer. I have a contact in Intelligence at Karachi. Someone gave me his reference who is our mutual friend. He says that if you want Danish to be picked up, then I can do it by making him disappear for two or three days from the scene. Let me talk to that person although that person is from lower cadre. But the person who referred me said that the contact will be useful. What I want is that what she sees ahead should be blocked. I am just sending him the details. He has some other companies if you check profile of Danish. He is CEO of Trek and Sell and Director of Singapore Company. You also find some contact there to pick him up. Osama was also suggesting me that if you can get him kidnapped for few days it will be better as she (Mehvish) is in touch with him. Who is this Zeeshan? It was from last dialed calls. Many of her contacts were lost due to the Data being wiped off. Now there are three Danish in her contact list: Danish Thanvi, Ali Danish. Let’s see what happens. Did you unlock her laptop? What did you get in it? Kindly check it thoroughly. Allah Hafiz

CALL AUDIO:

Listen online on Sound Cloud https://soundcloud.com/danish-thanvi/call-oftayyab-with-saqib-nov-8-2016-1304hrs Disclaimer: Automatic Audio Recorder (AAR) is a sophisticated sound-sensing application that starts recording when signal level exceeds the set threshold. What sets the AAR apart from other applications is the ability to fine-tune the sound processor. https://play.google.com/store/apps/details?id=com.itadapter.android.games.aar&hl=en

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IDENTITY THEFT AND CYBER HARRASMENT Soon after snatching the cell from Mehvish, her husband Syed Tayyab Ali Shah, took away all her identity which includes not only her CNIC but also her social media accounts. Her ATM card and cheque book was already taken by Tayyab, she suffered major financial crisis as she was unable to withdraw any money from her bank account. She had to present original CNIC which is a necessary requirement for the documentation by the bank for new account opening. Due to lack of funds and no transport (as her car was also taken by her husband), she was unable to attend the office. During this time, she missed important meetings with important clients. Like mentioned in the screenshot email she was unable to attend the meeting with client Affiniti on November 20, 2016. Her social media accounts like facebook, linkedin and gmail account was also taken over by her husband, Tayyab. As mentioned in the above provided recording where he is informing Lt Col Saqib Mumtaz that he has changed her facebook, linkedin and gmail password so she cannot access it. After changing her passwords on facebook and linkedin, he started to send foul messages to her contacts impersonating her identity. He has also sent similar messages to her facebook contacts. Mehvish requested facebook to take control of her facebook account again, however she was unable to do so due to lack of evidence of identity documents required by facebook administration.

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Irfan Maqbool who was from Mehvish’s professional network was contacted by her husband Tayyab on November 12, 2016 soon after the incident. He sent him foul messages twice while impersonating Mehvish

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FACEBOOK TECHNICAL SUPPORT WAS CONTACTED BY MEHVISH AS SHOWN IN THE SCREENSHOT BELOW TO RECOVER OF HER FACEBOOK ACCOUNT

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MEHVISH REQUEST TO GMAIL SUPPORT FOR RECOVERY OF HER EMAIL I D: S.MEHVISH.ALI@GMAIL.COM

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LEGAL REPERCUSSION OF THE EVENTS HAPPENING SINCE NOVEMBER 8.2016 The events which took place from November 8, 2016 carries serious legal repercussions in the light of Pakistan Penal Code (Act XLV 1860) and Prevention of Electronic Crimes Act, 2016. The Company

reserve the right to launch any legal action against the offenders. Following are the punishable offences: S r. 1.

Offence

Applicable Act

Defamation of Group CEO & BCG

Pakistan Penal Code (Act XLV 1860)

2.

Criminal intimidation by an anonymous communication

3. 4. 5. 6

Section Number Section 500 & 501

Punishment/Fine

Evidence

Offender

2 year Imprisonment or fine. Or with Both.

Mumtaz Shah

Pakistan Penal Code (Act XLV 1860)

Section 507

2 year Imprisonment or Fine. Or Both

Criminal Conspiracy against Group CEO

Pakistan Penal Code (Act XLV 1860)

Section 120-B

2 year Imprisonment

Public servant disobeying law, with intent to cause injury to any person Offence against dignity of a natural person Offence against the modesty of a natural person

Pakistan Penal Code (Act XLV 1860)

Section 166

1 year Imprisonment or Fine. Or Both

Prevention of Electronic Crimes Act, 2016 Prevention of Electronic Crimes Act, 2016

Section 18

Five years imprisonment with the fine of Rs. 5 million Five years imprisonment with the fine of Rs. 5 million

Letter written and distributed among the employees and exemployees of BCG Messages sent by cell number 03412699404 to employees & Group CEO Transcript of the call showing the plan to abduct Group CEO Planning to abduct Group CEO along with Tayyab Fabricated image of Danish & Mehvish Intent to take revenge

Section 19

Tayyab & Lt. Col Saqib Tayyab & Lt. Col Saqib Lt. Col Saqib Tayyab Tayyab, Lt. Col Saqib & Mumtaz Hussain Shah

CLAIM FOR DEFAMATION DAMAGE

The company can claim the damages of minimum Rs. 10 million against the defamation and character assassination of the Group CEO & BCG Management. The evidence provided in this dossier is sufficient enough to proceed with the legal action against the perpetrators.

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Hussain

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ANNEXURE 1: LETTER OF MUMTAZ HUSSAIN SHAH (FATHER OF MEHVISH)

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ANNEXURE 2: LIST OF CURRENT & EX EMPLOYEES WHO RECEIVED THE LETTER The list of current employees who received the letter by hand, email and through whatsapp message are mentioned below

LIST OF CURRENT EMPLOYEES

Sr.

Name

Job Title

1

Qaiser Hussain Abbasi

Assistant Manager

2

Noorullah

Watchman

3

Noratam Rama

Jr. Executive Research

4

Dilawar Khan

Assistant

5

Khizer Najmi

Verification Executive

6

Owais Ali Khan

Verification Officer

7

Muhammad Sharjeel

Manager Operations

8

Zane Hormuzd Tengra

Client Support Executive

9

M. Yousuf Khan

Admin Executive

10

Hasan Jamal

Senior Consultant

11

Muhammad Imran

Senior Executive HR

12

Rajesh Jeevan

Office Boy

13

Adil Waseem

Office Boy

14

Abdul Rasheed

Office Boy

15

Muhammad Imran Haroon

Manager Finance & Accounts

16

Saad Ahmed

Business Solutions Executive

17

Irfan ul Haq

Head of Business Solutions

18

Muhammad Omair Imtiaz

Junior PHP Developer

19

Ahmed Ali Ansari

Junior Officer

20

Zawar Hussain

Junior Executive

21

Waqar Ahmed

Web Development

22

Afraz Ahmed

Online Sales Executive

23

Muhammad Ahtisham Abbasi

Operations Executive

24

Syed Kazim Ali Rizvi

Administration Executive

25 26

Asif Zafar Syedah Mehvish Ali

Network Administrator General Manager

27

Raheel Khan

Verification Officer

28

Mohammad Jahanzeb

Verification Officer

29

Zeeshan Naveed Khan

Head of Technology

30

Mohammad Nauman Ali

Client Support Representative

31

Mohammad Shoaib Shahid

Operations Executive

32

Hassam Subhani

Senior Finance Executive

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LIST OF EX- EMPLOYEES

S.NO 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41

Name Ubaid Qureshi Saad Qureshi Saqib Mehmood Faisal Shaheen Niazi Muhammad Noor Syed Jahanzeb Saeed Jilani Ubaid Qureshi Abdul Majeed Suresh Paema Sunil Paema Rama Mohammad Nawaz Sultan Ali Abdul Rahman Muhammed Asad ul Haq Farhan Raees Siddiqui Jawaid Aslam Rohani Vasani Saima Butt Kanwer Irfan Saleem Muhammad Hammad Ali Elroy Edwin Van Milder Aneel Mehmood Nizamani Usama Akram Usman Ghani Govind Kumar Muhammad Hasham Ansari Mohammad Riaz Muhammad Shehzad Asadullah Jalbani Rehan Zaheer Atif ur Rehman Wasif ur Rehman Ghulam Asghar Sadam Hussain Shiraz Ahmed Siddiqui Asma Shahid Beena Sahar Govind Kumar Asad Jalbani Abdul Latif

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Job Title System Support Executive Office Boy Office Boy Network Administrator Gate Keeper Internee System Support Executive Office Boy Admin Officer Office Boy Office Boy Security Guard Chief Financial Officer Chief Financial Officer Manager Finance Assistant Manager Finance Assistant Manager Finance HR Manager HR Officer Sr. Executive HR Asst. Manager HR HR Manager Data Entry Operator Officer Internee Intern Research Analyst Rider Research Analyst Sr. Research Analyst Research Analyst Sr. Research Analyst Intern Intern Intern Research Analyst intern Officer Verification Officer Manager Operations Rider 47


42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86

Mursaleen Shah Atif ur Rehman Ghulam Asghar Qazi Shahroz Uddin Zeeshan Ahmed Mangi Syed Khurram Zahid Syed Faiz Hussain Jonathan Donald Nida Aftab M.Basit Gulzar Ali Mehboob Shujaat Ali Khan Nadia Adnan Nazia Manzoor Shagufta Iqbal Nazia Amir Furqan Shoukat Syed Muhammad Shahroz Mufti Muhammad Khalid Muhammad Saad Khan Saud Ahmed Shakir Latif Ghulam Mustafa Hassam ul Hasnain Shakir Ali Vikash Harjeewan Hamza Obaidullah Kazmi Arsalan Shabbir Najam Ahmed Siddiqui Shazan Sayani Noor Alam Ahmed Faraz Khalid Irfan Hina Rehan Noor Alam Kamal Anwar Muhammad Fahad Jilani Syed Waqas Hussain Syed Muhammad Shahroz Mohammad Farhan Hassam ul Hasnain Muhammad Sarwer Syed Saifuddin Dewan Zara Ali Imam Taha Ali Adil

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Officer Sr. Research Analyst Junior Executive Research Internee Sr. Research Analyst Head SEO / Marketing Sr. Online Marketing Analyst Data Entry Operator Marketing Executive Data Entry Operator Sub Editor & Marketing Support Executive Sr. Business Development Executive Executive Content Writer Executive Executive BDO Internee General Manager Online Marketing Executive Asst. Manager BD & HR Generalist Director Brand Strategy & Communications Asst. Mgr. UI & UX Development intern Intern Intern Asst. Mgr. Branding & Communications Assistant Manager Manager Blogs Manager Digital Marketing Intern Asst. Manager Marketing Manager Digital Marketing Content Writer Jr. Executive - BD Sr. Consultant IA & Vendor Head of Creativ Assist. Creative Designer Graphics Designer Senior Graphics Designer Jr. Graphics Designer Intern Group Head BD Asst. Manager Key Accounts Team Leader 48


87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 113 114 115 116 117 118 119 120 121 122 123 124 125 126 127 128 129 130 131

Osama Ahmed Momin Muhammad Talal Ata Raza Faraz Ahmed Siddiqui Faraz Ahmed Narjis Ayaz Ali Shah Farrukh Warsi Arsalan Hashmi Muhammad Maqsood ur Rehman Muhammad Sufyan Saad Asif Syed Sohail Ahmed Muhammad Adnan Khalid Asad Mairaj Hassan Abubakar Saddiqe Amna Khan Khawer Rabbani Zeeshan Naved Khan Rizwan Hidayat Khan Rabika Iqbal Faisal Mehmood Hasan Zaffar Adil Yousuf Butt Atif Abro Talha Kazi Dileep Kumar Muhammad Ayaz Naveed Akahtar Waseem Ahmed Abdul Jabbar Sameeullah Daris Saqib Ahsan Faraz Asad Ummer Shafiullah Faraz Ahmed Allah Bakhsh Soorih Kamal Anwar Hasan Jamal Talha Kazi Ayaz Ali Shah Muhammad Safdar Imam Syed Tashfeen Izan Riaz Noman Niazi

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Sr.Web 2.0 Developer Web 2.0 Developer Sr. Web 2.0 Developer Technology Manager Network Administrator PHP Web Developer Junior Web Developer Web Developer Project Manager PHP Web Developer Jr. Web Developer ASP .Net Developer Chief Technologist / Chief Executive Technical Writer Web Developer Internee Pre-Sales Coordinator Manager Communication Chief Technologist / Chief Executive Sr.Developer SQA Engineer Sr.Web Architect Team Leader Manager Engineering Project Coordinator Intern Intern intern Quality Assurance Analyst System Support Executive Trainee Developer Head - Enterprise Solutions Network Administrator Head - Technology & Communication System Support Executive system Support Executive Verification Officer Head Immigration Screening Junior Software Developer Web Developer Web Designer System Support Administrator Intern Creative Lead 49


132 133 134 135 136 137 138 139 140 141 142 143 144 145 146 147 148 149 150 151 152 153 154 155 156 157 158

S.M.Naqi Raza Syed Muhammad Showzeb Jaffri Uzair Haseeb Midhat Irfan Ilma Janib Owais Khan Muhammad Jameel Bilawal Baig Nitasha Khan Shujaat Ali Khan Muhammad Junaid Younus Umer Khan Zoya Abbasi Muhammad Kashif Mumtaz Sarfaraz Ahmed Abbasi S. M. Taha Anwer Marium Jawed Mirza Shaharyar Ali Baig Saima Qaiser Huma Ali Syed Muhammad Faris S.M.Naqi Raza Qazi Shahroz Uddin Sadia Qaiser Syed Muhammad Zafar Sana Akhtar Gill Kazim Ali

159 160 161 162 163 164

Faraz Ahmed Siddiqui Hasan Jamal Fariha Asif Riaz Ali Shah Daniyal Ahmed Siddiqui Ilma Janib

165 166 167 168 169 170 171 172 173

Erum Hanif Janib Soomro Hasan Zafar Shahzad Hasan Muhammad Rafiq Ghanchi Ata Abbas Mohammad Adil Shaikh Muhammad Shoaib Zoya Abbasi

EVIDENCE DISCOVERY DOSSIER - JANUARY 13, 2017

Product Specialist Assistant Manager Asst. Manager Digital Sales Internship Freelance Content Writer Manager Digital Sales & BD AVP Data Intelligence and Operations Sr. Creative Producer Business Development Executive Asst. Manager Sales & BD Assistant Network Supports Vice President Sale Internee Research Analyst Business Risk & Relationship Manager Internee Internee Product Development Executive Consultant Content Writing Services Vendor- Digital Marketing Services Vendor - Business Development Services Junior Officer Senior Manager Ops Driver Customer Relationship Officer Business Development and Marketing Consultancy IT Engineer Senior Consultant Junior Executive Senior UI/UX Designer Marketing Executive Vendor- Communications and Content Management Chief Human Resource Officer Sr. Manager Data Intelligence Senior PHP Developer Assistant Vice President Technology UI/UX Designer Junior Developer Lead UI/UX Developer Sr. Finance Executive Junior Executive 50


174 175 176 177 178 179 180 181 182 183 184 185 186 187 188 189 190 191 192 193

Maroof Sultan Temuri Khalique Ahmed Khan Servech Soomro Muhammad Athar Ali Khan Aziz ur Rehman Muhammad Bilal Ahsan Thanvi Saddam Hussain Munam Shah Samiullah Khan Bana Ghulam Ayesha Safdar Ramla Abbas S. M. Taha Anwer Saima Baber Zara Ali Shamil Ahmed Syed Khurram Zahid Muhammad Faisal Khan Yousuf Zai Zubair Ali Bhatti Shoaib Ahmed Mithani

Verification Analyst Software Developer Junior Executive AVP Risk Management and Compliance Internee Internee Jr. Executive Research Business Solutions Executive Office Boy Office Boy Customer Relationship Officer Business Solutions Executive Junior Officer Assistant Manager Asst. Manager Key Accounts Senior Technology Consultant Head of Product Development Assistant Manager Operations Manager Operations Assistant Manager (Relationship Management)

194

Khalid Karim Siddiqui

195 196 197 198 199 200 201

Feroz Ali Khan

HOD (Finance, Technology & Online International Sales) Assistant Manager

Muhammad Fahad Jilani

Creative Head

Syed Khurram Zahid

Head of Product Development

Zohaib Abdul Ghaffar

Asst. Manager Digital Marketing

Vikash Harjeewan

Jr. Officer Data Intelligence

Narmeen Mateen

Junior Officer

Mirza Rashid Baig

Senior Finance Executive

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ANNEXURE 3: STOLEN CELL PHONE REPORT TO PTA, CPLC AND CLIFTON POLICE STATION CPLC Complaint Number: 992610

COPY OF APPLICATION SUBMITTED BY MEHVIH’S ALI TO THE BOAT BASIN POLICE TO REPORT THE INCIDENT AND STOLEN COMPANY PROPERTY

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COPY OF THE APPLICATION TO THE CITIZEN POLICE LIAISON COMMITTEE (CPLC)

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SPECIFICATION OF MEH VISH’S CELL PHONE

IMEI: 356174079821495 Model: SM-J700H/DS Color: Golden Brand: SAMSUNG Manufacturer: SAMSUNG KOREA Serial Number: 982149 Type Allocation Code: 35617407 Luhn Checksum: 5 Price: Rs. 25, 680/Purchase Date: July 12, 2016 URL: https://imeidata.net/check?imei=356174079821495&g-recaptcharesponse=

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ANNEXURE 4: DESCRIPTION OF MEHVISH’S STOLEN LAPTOP

Laptop

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ANNEXURE 4: LAPTOP RECEIPT

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ANNEXURE 5: HOW TO MAKE A FAKE PICTURE WITH FAMOUS PEOPLE TO IMPRESS YOUR FRIENDS AND FAMILY COMBINING TWO PHOTOS WITH A PHOTO EDITOR

1. Choose a celebrity photo. Do an image search for the celebrity (or celebrities) you want to be with in the photo. o Look for a high-resolution image. You can always go down in resolution (that is, save a high-res image as low-res), but it's hard to go up. o Images taken against a solid colored background will work a lot better than a dynamic or moving background. o When you find one you like, right-click and save it to your computer. o For maximum believability, choose a seldom-seen photo of the celebrity. A casual snapshot might be better than a professional photo that's been plastered all over the Internet. http://www.wikihow.com/Make-a-Fake-Picture-With-Famous-People-to-Impress-Your-Friends-and-Family

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2. Choose a photo of yourself. Once you have the celebrity photo you want, find (or take) a picture of yourself to put into it. If you can, try to find an image that will blend well with your celebrity picture. For example, if there is a spotlight coming from the right on your celebrity image, choose a photo of yourself where there is a strong light source on the right. Also, pay attention to contrast - if the celebrity image is high-contrast, make sure the photo of you matches.

http://www.wikihow.com/Make-a-Fake-Picture-With-Famous-People-to-Impress-Your-Friends-and-Family

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3.

Open both photos in the editing program of your choice. Photoshop is popular but you can also find free image editing programs online such as Gimp. Gimp has all of the same popular features found in Photoshop and it doesn't cost a dime.

http://www.wikihow.com/Make-a-Fake-Picture-With-Famous-People-to-Impress-Your-Friends-and-Family

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4. Remove the background from your photo. Use the Magic Brush or Magnetic Lasso Tool to cut yourself out of your picture. use a remove brush to "erase" the background. You want the background to become a light white and gray checked background, this means that you are removing any background which will make it lay on top of the second photo better. 5. Drag the newly-cut image of yourself onto the celebrity picture. http://www.wikihow.com/Make-a-Fake-Picture-With-Famous-People-to-Impress-Your-Friends-and-Family

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6. Make adjustments. No matter how closely you tried to match the celebrity image, you'll probably need to make a few adjustments to the final product to make it look more realistic. Here are some things you could try: Use the eraser tool to get rid of extraneous pieces of background that came along with the image of yourself. You may also need to adjust the lighting or contrast of the photo. Make sure you look proportionately sized next to the celebrity (that is, not too short or too tall). You might need to shrink or enlarge the image of yourself. If this is not an option, try placing yourself in the foreground (if you're too big) or the background (if you're too small) of the image. Blend the edges. Drag the blur tool around the image of yourself. This will help your edges fade into the photo, making it look more realistic.

http://www.wikihow.com/Make-a-Fake-Picture-With-Famous-People-to-Impress-Your-Friends-and-Family

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7. Make sure you have a story ready. People will have questions about the picture. Come up with an amusing anecdote or believable story about how the photo came into existence. People will want to know what was in the gift.

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8. Drag the newly-cut image of yourself onto the celebrity picture.

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FIA Complaint for Cyber Crime and Evidence Dossier against Syed Tayyab Ali Shah and Lt. Col Saqib  

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