media inquiry from forbidden stories / please respond by

6/18/2019 Beach Minerals Producers Association Mail - Media inquiry from Forbidden Stories / please respond by June 18

https://mail.google.com/mail/u/1?ik=981f6da815&view=pt&search=all&permmsgid=msg-f%3A1636666852335424672&simpl=msg-f%3A163666… 1/21

President BMPA <[email protected]>

Media inquiry from Forbidden Stories / please respond by June 18

Sakthi Ganapathy <[email protected]> Tue, Jun 18, 2019 at 2:08 PMTo: [email protected]: S Vaikundarajan <[email protected]>, [email protected], [email protected],[email protected], [email protected]

Dear Miss. Cecile, I invite your kind attention to the mail correspondence you had with our company ManagingPartner Mr.S.Vaikundarajan. As advised by him, I am attaching herewith detailed reply withdocuments for your questions you are planning to use in the story. I hope that, you will honouryour commitment and you will not write things other than which are referred to us like SandhyaRavishankar. By believing you that, you will be a fair and conscious reporter , I am sending thereply to your questions on behalf of VV Mineral and Mr.S.Vaikundarajan. Your question : 1) The Amicus Curiae and the court appointed Satyabrata Sahoo Committee have foundvarious lapses on the part of the private beach sand miners. What do you respond to thespecific following points: (a) Mining in excess of permitted quantity (b) Mining and exporting during the ban period between September 2013 and 2017 (c) Evasion of royalties due to government (d) Monazite equivalent higher than permitted in stocks meant for export (e) Flawed mining plans approved without due diligence (f) Lack of necessary environmental, CRZ and other clearances Our reply : Before we give you replies to these answers you must know a little bit of history aswell. We have enter in this field 1988. Our competitor Mr.Dhayadevadas also doing the samebusiness in the name of Indian Garnet Sand Company and Southern Enterprises. To captureKorean market, our competitor Dhayadevdas visited Korea along with his Partner and Memberof Parliament R.Dhanukodi Adithan and met the customer. He threatened Korean customersthat, they have strong political power in India. The below telex message send to our ManagerMr. Yesu Selvaraj will establish the same.



Since he could not able to succeed, again he wrote a letter to Korea stating that, VV Mineral isdoing illegal mining. The Korean customer forward the same to us.



From 1988 itself, Mr.Dhayadevdas through his political power, filed more than 300 cases. Itsjust not God’s grace but also since the cases had no truth to it none of it succeed. Then hejoined hands with our family rivals / relatives who has enmity with us. So any story you see onus, is basically is virtually created by our competitors. Sandya Ravishankar, who is close aid ofDaya devadas, does she realise Daya devadas has more than 700 hectare of Mining leases inRatnagiri District of Maharastra to his Indian Garnet Sand Company and the mining leases inTamilnadu. Conveniently ignored or forgotten? Since the leases are close to the shore, will itnot cause sea erosion going by your theory?

Dhayadevadas could not able to compete with us in terms of quality. So if he want to stay in themarket, he has to stop our business. So engaged a group of knowledgeable criminal retired



officials and some biased and corrupted reporters like Sandhya Ravishnakar and plotted evilplans. Prior to 2008, Transworld Garnet India Pvt Ltd was a subsidiary of a Canadian Company andthey were a competitor to VV Mineral. Advocate V.Suresh was acting as a lawyer to TransworldGarnet India Pvt Ltd. During 1995-96, V.Suresh, Advocate along with two persons illegallytrespassed VV Mineral mining lease area of Irrukkandurai village, the security people detainedthe trespassers asking them to identify themselves. After a long argument and after givingapology letter, they were free to go. In fact the security team pardoned them instead of handinghim over to the police. He was upset about the detainment and has held grudge against VVMineral since then. Things didn’t go well for Transworld and they were auctions off for sale. Webid for that company and we took over Transworld during the year 2008. Obviously advocateV.Suresh no long acted as advocate for Transworld and refused any role in the company. Subsequently our competitor D.Dhayadevadas filed a PIL W.P. 1233 of 2012 in the High courtof Madras. On the above said case, Dhayadeadas make implead petition through his employeeV.Sundaram IAS (Retd.) through advocate V.Suresh. You can find out the above said facts inthe Madras High Court documents in M.P.No. 1 of 2013 in W.P.No. 1233 of 2012. So he is ourcompetitor’s Advocate who unfortunately became an amicus curie. This being the case, howcan we expect him to bring justice to the case? (you can find out that V.Sundaram deposedthat he was working Dhayadevadas for two years in a video which is attached. Anx-1 Again same Dhayadevadas filed another PIL through his employee Victor Rajamanikkam in thesame Madras High Court vide W.P.No. 1592 of 2015. The case was admitted for hearing andnotices were issued. Then we submitted the proof that, Victor Raja manikkam was workingunder Dhayadevadas and he was an interested party and it was not a public interest litigationbut a personal interest litigation. So the Honourable High Court severely warned Victor RajaManikkam and Victor Rajamanikkam himself filed apology affidavit before the High Court andrelieved from the writ petition. Since already writ petition was admitted for enquiry and noticeswere issued to respondents, the Honourable High Court converted the same as suo-moto PILand appointed one advocate as Amicus Currie. Unfortunately advocate of our competitor in theprevious PIL was appointed as Amicus Curie. More over Mr. V.Suresh was active member inP.U.C.L (a severe left wing movement against industrialisation and mining in general) andalready he was against beach mineral mining. In 1996 itself P.U.C.L submitted memorandumagainst Beach Mineral Mining. You can find out the same in the P.U.C.L Documents. So its quitnature to file reports against us. Whatever reports submitted by amicus will be subject to ourcounter and finally the Honourable High Court will decide the correctness of the fact. The Amicus Curie’s duty is to help the court to bring the fact and legal position. Unfortunately inthis case, the real facts are not brought to the knowledge of the Court. For example, the amicussubmitted the report based on the District Committee Minutes. Whereas, the above said DistrictCommittee is not constituted in accordance with law. According to MMDR Act, if a committee isconstituted, powers should be delegated by notifying in the official gazette and the constitutionitself placed before the Legislative Assembly within six months. This is the statutoryrequirements under section 26(2) and section 28(3) of MMDR Act. None of such statutoryrequirements are complied with in this case. The State Govt., itself replied in its letter No.15053/MMD.1/2017-1 dated 16.02.2018 (Anx-2) that, the said statutory requirements are notcomplied. Already Ministry of Mines, Tribunal in its Final order Nos. 151 of 2013, 152 of 2013,and 156 of 2013 which can be downloaded from Govt., of India, Ministry of Mines website andnumber of High Courts as well as Supreme Court orders decided that, without complying thestatutory requirement of notification in the official gazette, constitution of a committee is illegal.The above real fact is not brought to the notice of the Honourable Court by the Amicus Curie orhe did not mention the above lapse in his report. Moreover the District Committee also without jurisdiction acted, even without filing appeal. Theminutes was created suo-moto at the instigation of the District Collector. The District Committeehas no suo-moto power, which was also confirmed by the State Government vide letter No.15161/MMD.1/2017-1 dated 16.2.2018. (Anx-3)

http://m.p.no/

http://w.p.no/

http://w.p.no/



Above all, we vide our registered letter dated 10.10.2016, requested the District Collector toinform the date of hearing. So that, we will appear and submit our explanation if any required.But the District Collector without giving that opportunity to us, by violating the Principles ofNatural Justice, created the Minutes against us, only to make damage to us and give it to theselective media people like Sandhya and send it to Amicus Curie even without specific orderfrom the High Court. Based on the same, the Amicus Curie created the report and spreadthrough media to damage our reputation. Without following the Principles of Natural Justice andwithout furnishing copy to us, and without hearing our side arguments and our side documentswhatever minutes created, it become null and void. Already the Honourable Mines Tribunal, inits final order No. 3/2014, 6/2007 and 23/2006 decided the same which can be downloadedfrom Ministry of Mines, website.

The Hon’ble Supreme Court has decided as follows:-

(a) Principles of natural justice apply to any proceedingswhere the proceedings have civil consequences on theparties thereto. [2007] 3 SCC 587, (2008)14 SCC 151 &(2014) 9 SCC 105.(b) Natural justice requires that when an authority relieson certain documents for the purpose of an inquiry,then, copies of those documents must be furnished tothe party seeking the same. [City Corner vs. PersonalAssistant to Collector and Addl. District Magistrate,Nellore – (1976) 1 SCC 124; Kothari Filaments &Another vs. Commissioner of Customs – (2009) 2 SCC192].(c) Denial of the right to give a written response, andrefusal to grant personal hearing, are violative ofprinciples of natural justice. [Haryana State IndustrialDevelopment Corporation & Ors vs. Hari OmEnterprises – (2009) 16 SCC 208]

(a) Mining in excess of permitted quantity

Beach Minerals are unique in the world, that they are the only minerals which are‘replenishable’. The Amicus has recognized this fact in his report. Even the Govt., ofIndia also recognized this fact in the Nagar Committee Report. Chapter-III of NagerCommittee report is given below.



For your information, our competitor Dhayadevdas himself influenced to constitute thecommittee under the Chairmanship of Nager as he was very close to him. Fortunately,he and other members of other state and department officials refused to bend hisinfluence.

A replenishable mineral is one which Nature creates fresh reserves of, as and when theold reserves are removed. These are to be viewed in distinction from ‘In Situ Minerals’,which are gone once for all, once they are removed.

Such deposits of BSMs are called ‘placer’ deposits. Once the top layer of sandcontaining the placer deposit is removed, it will always be replenished by fresh actionof wind and tide. This unique characteristic of placer deposits makes it impossible toassess the full extent of reserves in any particular area, since the mineral isreplenished as and when it is removed. This fact has been recognized by theGovernment itself, which had constituted a Committee for this purpose, known as“Nagar Committee”. This fact has also achieved judicial recognition before this Hon’bleCourt in the judgment of this Hon’ble Court dated 04.12.1997 made in W.P. No.5386 of1997. You can verify the same from Madras High Court.

In all our mining plans, we have mentioned that, we proposed to mine a particular quantity fromthe insitue reserve and we will give preference in mining for the replinishable deposit



accumulated in the lease area. Govt., of India already approved the same, as, the aim of theMMDR Act is Development and Regulation. So conservation point of view, unless we failed tocollect the replinishable deposit, it become a national waste and there is possibilities for usageof this valuable minerals for domestic purposes such pilling the pits or construction etc., so thegovernment itself permit to collect replinishable deposit by approving the mining plan with suchendorsement. The State Govt., as well as District Collector also knows the same, theythemselves submit report that, only replinishable deposit alone collected. All our mining quantityare within the permissible limit. Already in 2007, the District Collector took the same stand andissue a notice. We submit our explanation that, it is naturally replinishable deposit, unless it isnot collected within stipulated time, it will become waste. The District Collector deputedsubordinate officer to verify the fact. Based on the report of the Sub-ordinate officer, the DistrictCollector accept our explanation and drop the show cause notice. So, other District Collector orDistrict Committee cannot re-open the issue in a later date. Moreover the Mining plan,production all are approved under the powers of Mineral Conservation Development Rules,1988. No State Govt., officer have been delegated power under the said rules. The TamilnaduGovt., itself confirmed the same vide its letter No. 3311/MMC.1/2018-2 dated 9.4.18. (Anx-4)So the Amicus report is without jurisdiction and created based on the illegal report submitted bythe District Committee which has no statutory power or duty. (b) Mining and exporting during the ban period between September 2013 and 2017 Please note there is no ban of mining. This wordings were cleverly used by the corrupt reporterlike Sandhya Ravishankar only to prejudice the judiciary. The State Govt., issued G.O. for thestoppage of mining operation and for issuance of transport permit until the inspection by theRevenue Secretary is completed. Stoppage of mining until the inspection is completed doesnot amount Ban of mining. Even for the said stoppage, the State Govt., has no power. We filedwrit petition in the High Court against the stoppage of mining operation and to change the Headof the Committee instead of Gagandeep Singh Bedi, since he has personal enemity with usfrom 1996 itself. We have already filed complaint before National Human Right Commissionand two other officers vide case No. 21/22/97-98. You can verify the same from the MadrasHigh Court pending writ appeal typeset papers. The writ petition was allowed by the Honourable High Court setting aside the stoppage ofmining operation portion of the G.O., as there is no power to the State Government forstoppage of mining operation since it is major mineral and comes under the control of CentralGovernment and instead of Gagandeep Singh Bedi, a Retd. High Court Judge was appointed,as Chairman of the Committee. Since the Govt., want to fix up us by getting Ex-party report,they filed appeal and the Writ Appeal is still pending. We have already paid royalty and transported with valid transport permit for at about 98lakhs(9.8 million tonnes) M.Ton from 2000-01 to 2012-13 and we have exported less quantityalone. At present we have approximately 36 lakhs (3.6 million) M.Ton of royalty paid stock withus. This has been confirmed by the High Court appointed Sahoo Committee inspection also.But since Sandhya Ravishankar’s duty is to prejudice judiciary and to make false storiesagainst us, she has told that, export after mining ban. There is no ban for export and Exportdoes not comes under the purview of MMDR Act. Govt., of India, Ministry of Mines confirmedthe same vide letter No. 16/01/2016-M-VI dated 10.10.2016. (Anx-5) Once the mining is completed and once royalty is paid, the State Govt., has no control over themineral. This has been decided by the Honorable Supreme Court in Cavery Chetty Vs. Union ofIndia case. (c) Evasion of royalties due to government We are not evading royalty. We have paid royalty for 98 lakhs M.Ton whereas our total export isless than the same quantity. Please note there is no royalty for waste sand, the royalty is onlyfor minerals alone according to section 9 of MMDR Act. Moreover for calculation and collectionof royalty, then and there the Central Govt., alone can frame rules. Everyone has to follow the



said rules. All our royalty paid accounts were every year, scrutinized by the AccountantGeneral office and some time they have remarks about the calculation of royalty by the officialsor collection of royalty etc., If such report is received, immediately we will remit the same. Sothe allegation you have mentioned is execrated by our competitor’s media person SandhyaRavishankar. (d) Monazite equivalent higher than permitted in stocks meant for export The Honourable High Court appointed Sahoo Committee to find out the stock of all the lesseesin Tamilnadu. According to his report, our stocks are in accordance with our declared quantityand the difference also within the tolerance limit of 10%. They have taken sample from all thelessees from Tamilnadu with a plan to prepare report against us in collusion with one AssistantDirector, our competitor Dhayadevadas influenced the committee members not to follow thestatutory procedure such as inspection and taking samples in our presence and handing over ofcounter samples etc.,. So immediately we filed a writ petition that, the inspection and thesampling of Sahoo committee should be in our presence. So the Sahoo committee submittedcorrect report in respect of us without the influence of our competitor. Only in the case of IREL,Government owned company the monazite equivalent is higher than permitted in their inventorymeant for export. As long we are well within the norms and we can’t comment on IREL’sproblems. But conveniently your friend Sandya must have hid the same and said companieslike us have violated. (e) Flawed mining plans approved without due diligence The mining plans are approved by Govt., of India under MCDR 1988. The mining plan can beprepared by a Recognized qualified person (RQP) who possess the statutory qualification andexperience under the said rules and registered by Govt., of India. In case, any wrong in themining plan, the affected person can file appeal before the appellate authority. As far as oursare concerned, based on the instigation of our competitor Dhayadevdas, the RegionalController of mines, purposely returned our mining plans and suspended the mining operation.So without other option, we have filed writ petition before the High Court which was allowed.Against the same, Govt., of India, Indian Bureau of Mines filed appeal before the DivisionBench. The Division bench, while deciding the appeal, directed that, whatever information IBMrequired, it should be collected from us within 15 days, we should submit the same within 30days from the date of receipt of letter and IBM should approve the mining plans within another30 days. Accordingly all our mining plans were approved as per the order of the HonourableHigh Court. So, except this episode, we have no problems with the mining plan atleast to ourknowledge. Any thing is purely a false allegation. (f) Lack of necessary environmental, CRZ and other clearances Mr. Dhayadevadas obtained one mining lease in Padukapathu village of Periyathalai hamlet. He filed a writ petition asking police protection. The padukkapathu village people filed a writpetition stating that the lease was granted without getting CRZ Clearance and it well degradethe environment, it will create sea erosion etc., Govt., of India, Ministry of Mines, Ministry ofEnvironment and Forest, State Govt., various departments are respondent on the above saidcase. The Honourable High Court in its Judgement in W.P 11971 and 15451 of 1995 dated 9.9.96categorically decided that, there is no violation in grant of mining lease even without CRZClearance. Beach Mineral mining will not create sea erosion. It will not degrade environment. You can get the above said judgement either from your Sandhya Ravishankar or any one ofyour colleague from the Madras High Court. Even though there is a judgement supporting that this mining this will not affect environmentetc., we always have the practise of following due statutory compliance, so we have obtainedall the clearances for all our mining leases and our mining operations are within the tolerancelimit and environmental clearance limit.



We have explained all of the same in detail in the objection to the Amicus report submitted tothe Honourable High Court. If you go through the same you can find out more. Previously also the same Dhayadevadas filed a writ petition in the Madras High Court againstthe Environmental clearance granted to us through his henchman Thiyagi Ponnaiah Pillai. Afterperusing the records and counter, the Honourable High Court dismissed the writ petition in W.P.No. 25807 of 2006 dated 17.11.2006. So this allegation is false and without any basis. Since the Amicus report is not in accordance with law and since he did not submit the reportaccording to law, by narrating all the above facts we have submitted objection to the Amicusreport before the Honourable High Court under various headings, such as, the Errors in thereport of the Amicus and errors in method of calculation all are mentioned in our objection filedbefore the Honourable High court, as the Amicus report was prepared based on the DistrictCommittee report which is prepared without any jurisdiction and power and prepared withulterior motive. The amicus report is mainly used only to make negative report against usthrough media. Whatever reports submitted by amicus will be subject to our counter and finally the HonourableHigh Court will decide the correctness of the fact. Since you have discussed about Amicusreport, I hope definitely you will discuss the objections to the amicus report which was also filedin the same case. In this case, whatever you have mentioned about Amicus Curie report, we have already filedour objection in the High Court. Till today no order is passed about this Amicus report and ourobjection. Unfortunately, your contact Sandhya Ravishankar cleverly might have sent you acopy of Amicus report alone, intentionally ignoring our objection given to the court. Please askher to send copy of our objection submitted to the amicus report which is available in the samecourt. Then you will know the truth. The reasons that she did not submit the report is we haveclearly mentioned in our objection before the same court how the amicus curie report is wrongand how we are acting in accordance with law. For your reference, I am attaching herewith theobjections filed by us for the Amicus curie report in the High Court. First 28 pages will explainthe back ground and the nature of industry etc., From page 29 itself we have filed our objectionin the following captions. (Anx -6) V. OBJECTIONS TO THE REPORT OF THE LEARNED AMICUS:

This paragraph may be subdivided into the following:-

V.1 Purpose for which learned Amicus was appointed to assist the Court

V.2 Scope of the present proceedings

V.3 Sources of data which form the basis of the learned Amicus Report

V.4 Errors in the learned Amicus Report

V.5 Omission of Dhaya Devadoss in Amicus Report

V.6 Correct positionIf you go through the above said report, you can find out that, all the allegations made byAmicus Curie is without any basis and not in accordance with law. Since the W.P. is stillpending and the matter is sub-judice, we could not able to give you more information on thisaspect. Your question :



2) Now that the Centre has amended the Mineral Concession Rules, private players seem to bedisallowed from mining Beach Sand Mining. How does this affect you? Our reply : This has affected not only all the private heavy mineral manufacturers but in fact ithas affected a whole lot of people relying on this trade. About 75,000 employees who relied onthis trade lost their livelihood. All the supplementary businesses, like packing materialmanufacturers, truck owners, freight forwarders, allied serviced provides all lost their business. In fact two critical ports Tuticorin and VIZAG lost their cargo volumes. A huge amount ofFOREX inflow in India has been impacted at least to the tune of 3,500 crores per year. Biggestimpact is that the customers who relied on these material overseas lost trust in Indianproducers. They consider India to be a sovereign risk and will be afraid to deal with any Indianproducers going forward. Due to this infighting and bureaucracy going along with that in-fighting, have skewed the policy curtailing any private parties in this industry. Unless theGovernment changes its stance, India’s reputation as a reliable trade partner will take a serioushit. The revenue that is due to India is being enjoyed by competitive producers like Australia,Sri Lanka, Indonesia and South Africa. Country with more than 1/3rd of the total world reservehas to reconsider the decision. Your question : 3) You have said in an earlier interview that you paid bribes to get environmental clearances foryour mining. Can you elaborate on what actually happened? Our reply : This is another misrepresentation of facts by our competitor Dhayadevadas. Infact he pursued the same case in the court and failed. Many producers are arguing on the highfees fixed by state Government for getting environmental clearance. On that occasion only weproceeded forward by paying the fees. In a meeting our MD said “when you are all fightingover a fee, I have paid the amount and got the clearance”. As usual our friend Dhaya devadaswas trying to capitalise on this opportunity and misrepresented that as if we agreed that wehave paid bribe. Meanwhile it was purely statutory payment to Government. He even filed apetition by misrepresenting the same in the court that, I have confessed that I was giving bribeand requested CBI enquiry. Since the CBI has informed in the court that our competitorsallegation is false, the Honourable High Court dismissed his claim vide W.P.No.16924 of 2012dated 01.10.2015. So this is false allegation made by corrupt reporter Sandhya Ravishankar purely to tarnish ourreputation to favour Dayadevadas. In fact the whole meeting was about Dayadevas trying toget a chair position in CAPEXIL (an export promotion council for chemical and mineralproducts). Since we and several others pointed out to the committee that he has been aviolator of rules and was already penalized for illegal mining, and demanded a fair electioninstead of just a nomination, the election was deferred. So, this incidence hurts him so Sandyais raising it as issue. Copy of CAPEXIL processed mineral panel committee meeting minutesdated 12.11.2010 (Anx-7). We have obtained all the environment clearance in a legal route, following due procedures. AsI said any case filed against us by his henchmen against the grant of clearance also dismissedby the Honourable High Court and confirmed our legality. Whereas Dhayadevadas often tries to use political clout and influence the statutory authoritythough his company Director cum Partner Dhanuskodi Athithan, Member of Parliament, LokShaba and get all the clearances without following the statutory procedures. The below photowith the then Prime Minister which is purely a lobbying exercise to influence the bureaucracy.



I also attached Govt., of India, Department of Atomic Energy letter No. 48/4 / 95/AMD/R&D-I /302 dated 23.6.95 (Anx-8) which is copy of No objection certificate issued to Indian GarnetSand Company by Atomic Energy Department with a copy to Dhanuskodi Adithan Member ofParliament. This will show you that, how politically powerful this gentleman is and how he canable to give trouble to law obeying citizens. Your question: 4) IBM has done an internal inquiry and has found a number of lapses in approval of miningplans to beach sand mining firms. Do you wish to comment? Our reply : As I already explained you that, our competitor has political clout. He threatened allthe officials that, next government will be Congress government, unless the officials are nothelping to his illegal things, when Congress government came to power, the officials will bepunished. You know very well that, Judas betrayed world saver Jesus for merely 30 piece silvercoins. So some of the officials who afraid tried to help him and appointed a committee withselective people selected by Dhayadevadas. We file a petition to hear our side also which wasrefused by the authorities. So we filed a writ petition in the High Court through our association.At the time of hearing, the government gave an undertaken to the court that, it is merely adepartment committee to find out the lapses done by the officials and the committee report willnot be used against the petitioner’s members including us without furnishing copy and withouthearing our side views. Based on the undertaken, the Honourable High Court closed the casevide W.P. No. 557 of 2019 dated 11.02.2019. You can verify the same from the High Court. Until now no such report copy was received by us or notice was issued to us. So we have noidea about the same. From your question, we can understand that, Sandhya Ravishankar hasnot only nexus with our competitors and Retd. Officers but also with officers who are in service. So we are not aware of any report by IBM against us. If you do have such report, kindly provideus so that we can answer the same. Your question : 5) The Tamil Nadu government included monazite in a number of your mining licences from2010, 2012 and set a royalty for its export. Amicus Curiae has said in his report to court that



monazite seems to have been mixed in with the other BSM and exported, thereby causinggreat concern to national security since it is an atomic mineral. Do you wish to comment? Our reply : For Amicus report, I cannot speak more than what I have mentioned in myobjection before the court , as the matter is sub-judice. We have given detailed explanation inour objection to Amicus report. You can go through the same. Once Central Governmentapproval is obtained for one mineral for a particular area, for inclusion of associated mineral forthe same area, there is no need to get again Central government approval. This has beendecided by the Honourable Supreme Court. All our mining leases are granted only withapproval from the Central Government. So for inclusion of associated mineral, there is no needto get approval again from Central Government. Monazite is an associated mineral in the beach mineral mining lease. If you go through themining plan approved to Indian Garnet Sand Company, our competitor, the great gentlemenwho filed PIL against us in the name of monazite Dr.Victor Rajamanikkam himself prepared themining plan for Mr. Dhayadevdas. He has specifically mentioned in the mining plan that, theraw sand contain radioactive material such as monazite etc. So they got NOC. The relevantportion is given below.

Until today, either no investigating media people is ready to ask about the monazite. It ispertinent to point out here that, the amicus also did not speak about this in his report. But hespread the report to the media and make damage to our reputation. Can you please ask checkwhat happened to the monazite of Indian Garnet Sand Company (IGSC) and SouthernEnterprises? You very well know the monazite tailings in our operation is all well accounted forand stored as per the regulations, inspected frequently by the authorities. But what happenedto IGSC’s monazite tailings? I am sure you, an abled fair journalist bring that to light. If the monazite is mixed with other minerals, it becomes a contamination and no country willpermit our product to import to their countries. You also know very well that, monazite is freelyavailable all over the world and there is no demand for monazite except for producing rareearths elements. The least amount of Uranium is not recoverable at a commercial scale andThorium available in the monazite are not fissile material, hence there is no use either in thenuclear power plant or in any other activities. This subject is purely used to create a scare theofficials who don’t understand these material very well. Radioactive scare is an easy tactic tohalt any progress on this sector. France is a leader in nuclear power, you yourself can confirmwith the experts in this industry from your country, if Thorium is used in radioactive powergeneration or doing any nuclear activities anywhere in the world? Or you can also ask if



Uranium is currently extracted from Monazite anywhere in the world? You will know the truth. So your wordings about a threat is the wordings commonly used by persons like SandhyaRavishankar to make fear in the minds of judiciary as well as the Government officials. Youplease take a learned decision not be guided by foolish arguments of the competitors. In facteven in India, our scientists have high hope on Thorium and are only conducting research ifThorium can be used in future reactors after a research period of another 30-40 years. All over the world no nuclear power plant is running by using Thorium and as on date, noThorium available in the Monazite is used for any nuclear purposes. This has been confirmedby Atomic Energy Commission Chairman vide his letter dated 19.03.2018. When there is nodemand and no use, in any part of the world, what is the necessity to handle the same? Butyour colleague Sandhya has the necessity to spread the news as she has remunerated only forthat. All over the world, researches are going on to run the car through sea water. Like that, all overthe world researches are going on to use thorium in the nuclear power plant. So the threat tothe nation etc., are the wordings used by the paid news reporter Sandhya. Please don’t usesuch type of misleading words. For your information, in India all the sea ports, Airports andother national borders were equipped with gadgets to find out radioactive materials. If it ismixed with other material then also it can be find out. You can see this from reply to parliamentquestion no. 896 dated 20.12.2017 (Anx-9). All our exports are through Tuticorin Port and Tuticorin Port also equipped with this facility, Nosuch unwanted radioactive material transportation is found by the authorities. This has beenconfirmed by Customs Authority of Tuticorin vide their letter C.No. 1/22/01/2012/RTI dated22.6.15. (Anx-10) Based on the request of the Amicus curie, the Honourable High court appointed a High LevelCommittee (Sahoo Committee) to quantify the mineral stock. They took samples of exportconsignment as well as other materials. Our competitors plan was to influence in submitting areport against us. By smelling this, we filed a writ petition in the Madras High Court that, allsampling should be in our presence and counter sample should be given one to us and one tothe High Court Registrar. So Sahoo committee took samples in our presence and hand over thecounter samples to us. The Sahoo committee samples were analysed by AMD. According toAMD report, all the private parties export consignment are without monazite content or belowthe threshold value. Whereas, Government company IREL’s export consignment alone containmore than the threshold value. But the corrupt reporter Sandhya instead of writing the same,turned it against us. If you ask Sandhya or your source, to furnish copy of Sahoo Committeereport available in the Madras High Court, you can find out that, our stocks are in accordancewith the quantity declared by us and the monazite stocks also tally with the accounts withrespect to us. The Sahoo Committee in his report mentioned, two factories one is Kuttam and one is Arasur(both are not belongs to us) did not tally the monazite tailings. But since Sandhya got moneyonly to damage Vaikundarajan and VV Mineral, she has wrote such type of false stories ormisguide you by giving false information. Please get Sahoo Committee report from her or anyof your source report and find the fact. For your ready reference I am giving below the extract of Sahoo Committee report withreference to declared as well as found quantity of mineral stocks.



The above will explain you that the quantity with reference to our company is within thetolerance limit of 10% plus or minus. Your question : 6) Can you confirm you have exported monazite as such to foreign countries? If so, to whichcountry was this monazite exported? Our reply : We are not exporting either monazite or any other radioactive material to any of thecountry. This is a false accusation made by the Sandhya & our competitor Dhayadevdas. If yougo through the video available in www.beachminerals.org/videos in English version which hasalready attached as Anx-1 , you can find out a team of people including top level retired officersall are working under our competitor Dhayadevadas with malafide intention to damage us.Sandhya Ravishankar also one of the gang member and her main work is to make fear in theminds of the judiciary and thereby avoid the hearing of the case pending in Court of law. So shemay create false and imaginary stories. Classic example is the link available in https://www.youtube.com/watch?v=2RqglwnF4AI Corrupt reporter Sandhya Ravishankar and daya devadas has an agenda to smear ourreputation and hence they start these kind of rumours. Government has confirmed multipletimes no private company is either producing or exporting monazite, they have also confirmedall ports and outlets of the country is fitted with radioactive meters. Even cargo ship these dayshave these counters to protect their ship and crew. Even a small amount of radiation in anymineral we export (ilmenite or garnet or zircon) is a contamination. All countries have a strictnorm on the radiation levels they can accept. So, no chance of monazite leaving the countryeven in traces. The competitors try to raise a question through a known MP in the Parliament

http://www.beachminerals.org/videos

https://www.youtube.com/watch?v=2RqglwnF4AI



and for one of the question, the Honourable Minister has replied that, regarding the media newsof illegal export, it is imaginary report without any basis. The Honourable Minister furtherinformed that, the AERB survey inspectors are periodically checked for the tailing disposal. Thiswill establish that this false news was spread by Sandhya. You can find out the same in reply toParliament question (unstarred) No. 1872 dated 9.3.16. (Anx-11) For your information, the isotope of Thorium available in Monazite is Th232 which not a fissilematerial. Hence there is no use in any part of the world. But “since monazite is a radioactivematerial and occurs in association with other placer minerals and with the necessity toregulate and monitor the monazite generated from the radiational point to preventenvironmental pollution, beach sand mineral producers are instructed to dispose off themonazite rich tailings as per the direction of AERB following all safety norms”. You canfind out the same from DAE letter No. 3/13(2)/2012-PSU/10123 dated 5.10.12. Most importantly the AMD has surveyed several years back the entire coastline of India andhas estimated the monazite content available in the coastline. After several years later, whenthese mining leases were all granted in some of those areas, all the companies were givenguidelines to treat the monazite tailings. AMD has in fact confirmed based on the currentoperation level and their previous available calculation seems to tally. What more proof youneed? Your question : 7) You are fighting a legal battle with the Centre for getting permission to crack monazite. Whatis this for? Our Reply : Not only us, All the beach mineral producers once approached Government to considerallowing private companies process Monazite. Purely because Monazite contains 65% of rareearth elements which can convert India in to a super economic power, bring tremendousemployment and industries to India, of course a lot of FOREX too. In fact we insistedGovernment to remove the radioactive elements (Uranium and Thorium) themselves and giveus only the non-radioactive part (rare earth elements in it). FYI, Monazite has about 65% ofrare earth elements, 25% of phosphates, 9% of Thorium and a very small 0.2% of Uranium. Countries like China, Australia, USA, Malaysia, etc., have proven Monazite can be processedby private companies by safely handling the radioactive rejects. We also like other heavy mineral producers wanted a role in rare earths elements. Weapproached Atomic Energy Department for permission. We have proposed to them earlier that,I will establish the factory and atomic Energy Department officials can operate the same aftergiving rare earths elements to me. They can take the Uranium and Thorium for their safecustody at my cost. But they did not agree with that proposal. Even as per the Act, whollyIndian owned companies are eligible for handling beach minerals. Hence we filed writ petitionwhich is still pending. Since the matter is sub-judice, I cannot reveal more details on this. FYI, Japanese company Toyota currently holds a JV with IREL to procure their rare earth oxideand they are doing individual rare earth separation in their own facility in VIZAG. We alsoproposed for a similar structure to give us only rare earth oxides (free from uranium or thoriumor any radio active elements). But unfortunately thanks to our competitors smear campaign,the country has shut the doors for any such progress. If this is the case, India will only be aspectator in this rare earth sector, when the real performance will come from China, Australia,etc. Your question : 8) Your clients like Barton, Ampeco and other firms in Europe have lobbied for lifting of the ban



on beach sand mining with the Centre? Were you involved in this process? Our reply : We have no idea about this. If you have any information or copy, please furnish it.So that, I can give you reply after verify the fact. Your question : 9) Scientists (most notably at the United Nations level) have written about the environmentalimpact of sand mining, especially illegal sand mining. What measures do you have in place tomake sure that you are not hurting the coasts of Tamil Nadu? Our reply : Please note beach mineral mining is not a sand mining. It is entirely different from sand mining.The origin of the mineral are kondolite rocks from Western Ghats. Due to the weathering itdistinguished and in sand form it was transported through rivers in to the sea. The sea due tothe sea current and due to the direction of the wind and wave action, deposited near theseashore. Part of the minerals will further transported to the adjoining areas, if it is not collectedwithin a limited time, the minerals deposited between the inter tidal area will be taken back anddeposited in the other areas. It is a continuous process, once the replinishable deposits arecollected, it will refilled due to the continuous wind and wave action. The quantity and thepercentage may vary from place to place and time to time. But it is easier than agricultureactivities. If you want to plant a coconut sapling you have to dig minimum one meter. Whereasthis replinishable collection of beach mineral is by scooping method. You can find out thereplinishable video in our association website www.beachminerals.org/videos For your readyreference I attached herewith as Anx-12. There is no need to blasting or bore holing, nochemical is used for processing. Hence it is completely environmental friendly industry. Moreparticularly mining and mineral processing method of VV Mineral is environmental friendly andhelped to reduce Global warming. You can find out in detail in http://www.icontrolpollution.com/articles/role-of-vvmineral-in-reducing-global-warming-throughgreen-mining-technology-of-garnet.pdf. “With heavy withdrawal of ground water both for industries and for drinking purposes cities likeShanghai have started sinking and millions of litters of water are now being pumped into theaquifers. We should peruse the concept of ecological recovery”. The above said observation isin the “Voices for the Oceans - A report to the Independent World commission on theOcean” prepared by the International Ocean Institute will establish the need of the complyingenvironmental laws. That is why we have obtained proper environmental clearance establishedseparate environmental lab with two doctorate in Environmental science to maintain theecology and environment of our mining as well as factory and surrounding areas. For your information, we are the only company operating with valid environmental clearance aswell as consent of the Pollution control board under Air Act and Water Act. So theenvironmental degradation is an imaginary story spread with ulterior motive. None of our area isaffected environmentally. Moreover we have won “Best Environmental Maintenance Award”from the Director General of Mines Safety more than three times. So this is the imaginaryallegation spread by your colleague Sandhya Ravishankar. This is a well organised industry governed by 26 different Government departments. We onlyrecover 20-40% of mineral and rest is refilled in the same mining area. Also out of 8000 kms ofcoastline in India, these minerals are extracted only in about 15-20 kms stretch in Tamil Naduand Andhra Pradesh. Most of the operation is atleast 500metres away from the shoreline, insome case it is even 4 kms away from shoreline. Out of 80 odd leases in India, only 3-4 leasesgives access to mining close to shoreline. You as a learned journalist very well know the realreason for sea erosion is climate change. The sand mining threat you are talking about is construction sand mined all over the world,whereas here in India, construction sand is mined mainly in river bed.

http://www.beachminerals.org/videos

http://www.icontrolpollution.com/articles/role-of-vvmineral-in-reducing-global-warming-throughgreen-mining-technology-of-garnet.pdf



Our competitor Daya devadas and Sandya’s clever wordings will confuse the heavy mineralmining with sand mining so that this can be created in to a big issue. Erosion issue is a world vide issue. Due to Global warming the sea level is raising and theshore line is affected. Since we used to operate all our mines, in accordance with the terms andconditions of CRZ as well as environmental clearance there is no damage to the shoreline. Wehave mentioned at length to a reply to Mr. Ashish Malhotra since you are also associated withhim. Hence you can see our reply to him through this link https://vvmemp.blogspot.com/2019/06/sandhya-ravishankar-and-her-gangs.html Your question : 10) High number of chronic kidney diseases have been reported among local populations livingnear beach sand quarries and processing plant in India, particularly in the village of Uvari whereV.V. Mineral operated. Are you aware of such health issue and have you financed any medicalsupport for this persons or any study to investigate the matter ? Our reply : I did not expect such a silly question from you. In case Sandhya hasrecommended you ask this question then you have to reply that, all over the world chronicKidney diseases are common. So this allegation is not correct. I don’t know for which you failedto refute such type of counter to her. Any how I explain you. Our own houses are close to the beach mineral factory. In our mines and factory, more than4600 employees were working. None of the employee affected either by Kidney disease orcancer. This has been proven by the yearly medical check up taken among the employees. Moreover our mining area and processing plants are minimum 500 meters away from thehabitation. According to the Director General of Mines Safety norms, 200 meter distanceenough. Whereas, we have kept 500 meters distance from the habitation. Also all the mining isdone about the water table. Then how it is possible?

Kidney diseases are common all over the world and are not limited to any specific areas. Infact, especially near Kerala, where IREL’s operation exists, naturally occurring beach sandscontain the radioactive mineral named monazite in high percentage. Even there,Epidemiological studies on the cancer incidence rate carried out in these areas indicate nocases of health problems, cancer or kidney failure in these areas which can be attributed to thebackground radiation levels. In fact Government has regulations to maintain the back groundradiation levels in all the coastline areas. This is the study report by Government of Indiaavailable in https://aerb.gov.in/images/PDF/f1.pdf (Page 54)

Given below are a few devastating statistics about chronic kidney failure in India.

1. 17% of Indians have some form of chronic kidney disease. This figure was reached that ina study conducted by Harvard Medical School in partnership with 13 medical centres allover India. One third of the above people have advanced stages of the disease.

2. There are 60 million people with diabetes in India, more than any other nation on theplanet. Sadly, the majority of them are either not diagnosed or poorly treated.

3. At least 30% of diabetics will develop chronic kidney disease because of diabetes.

4. People with the last stage of kidney failure (technically called Chronic Kidney DiseaseStage 5 or CKD-5) require dialysis and/or kidney transplantation as a life sustainingtreatment. 40 % of such patients would have developed kidney failure because ofdiabetes.

https://vvmemp.blogspot.com/2019/06/sandhya-ravishankar-and-her-gangs.html

https://aerb.gov.in/images/PDF/f1.pdf



5. 2,00,000 new patients need dialysis treatment every year in India. but the unfortunatereality is that only 10 to 20% of them get proper treatment. The remaining are either notdiagnosed or unable to continue proper treatment.

6. Statistics suggest that there should be almost 20,00,000people on dialysis in India as oftoday. The reality is that there are only about 1,00,000. The rest have been lost due tonon-diagnosis and non-treatment.

7. The majority of chronic kidney failure patients are diagnosed in the last stage. Thoughproper statistics are not available, it is accepted that almost 50% first see a nephrologist(kidney specialist) only in the last stage.

8. There are 0.4 dialysis centers per million population in India. By contrast, Japanhas 20 dialysis centres per million population.

9. Only 4,000 kidney transplants are performed every year in India. The United States withone fourth the population of India performs 16,000 such operations per year.

10. Kidney failure can affect people of any age group. While in the west, the majority ofpatients are elderly, in India kidney failure patients are much younger and affectspredominantly the working population.

11. High salt consumption (dry fish) or any foods with high salt consumption can also be apointed as a contributor to Kidney problems

Source : https://www.practo.com/healthfeed/some-devastating-statistics-about-chronic-kidney-failure-in-india-10945/post

This will establish that, a common disease available world wide is used to damage a particularcompany by a section of people with the help of some medias. Is it fair? Your question 11) We have been told by villagers around Thisayanvilai that they are afraid to talk about V.V.Mineral. Are you aware of this climate of fear? Do you wish to comment? Our reply : Please note no village people is against the mining operation. Only the vested interest peoplewho are working under Sandhya or Daya devadas alone speaking against mining. For yourinformation, Where in the video attached as Anx-1, you can find out even an Retd. IAS officerare working under the instruction of our competitors and they gave interview against us as perthe advice of our competitor. Also a person Anton from one Fisherman village to whom ourcompetitor is educating how to show emotions to spread false message against us, whentalking to media can also be seen. It is similar set of people who are misguiding you. Your question : 12) Journalist Sandhya Ravishankar has accused you of trying to intimidate her following thearticles she wrote about your activities. CCTV footage of her meeting a source was published,she says she was followed by private detectives. She makes a direct connection betweenthose incidents and you. What do you respond to those accusations?

Our reply :

Please be informed Sandhya Ravishankar has personal enemity against our company. Ourbusiness group also owns a reputed local TV News Media since 2014. During its initial phase,Mr.Prem shankar (none other than Ms.Sandhya ravishankar’s husband) approached us to

https://www.practo.com/healthfeed/some-devastating-statistics-about-chronic-kidney-failure-in-india-10945/post



manage the media operation. But we denied the opportunity. There started the enmity. Shestarted her partnership with Dhaya Devadas only after that. Like I told you before, Sandhya represents our competitor Dhaya devadas who was founddoing illegal mining and their operation was shut in 2011. He couldn’t bear the thought of otherproducers continuing to capture the market share, he took it upon himself and determined tobring down the entire industry. Slowly he launched smear campaign against us in 2013,instigated the then Government to bring mining ban. Since then he has been continuing theattack this industry and all the producers with baseless and false accusations. Sandhya is oneof his close aid. We initially thought she was fair and unbiased, met her few times, providedwith all the counter facts on accusations made by our competitors. But she chose to ignore itand carry only the competitors false versions. So, we have in fact filed two defamation suitagainst her. This has only made her furious to continue with her personal attack on us. We strictly believe in taking only legal action through court of law. Already two criminal casespending against her in Judicial Magistrate court and one case is pending in the High Court, andshe herself filed a case against me in the City Civil Court, Chennai. When we filed detailedcounter to scrap the plaint, the Honourable City civil court, Chennai accept our plea and scrapher plaint and dismissed the case filed by Sandhya Ravishankar in O.S.No. 1649 of 2017. We are a reputed organisation and always taken a legal recourse for any of the issues weface. Threatening the journalist is the last thing we will do. Can she provide one evidence toprove this? She can’t. I pity her situation because she has been jumping media organisations for every 3-4 monthsand she tries to use that media to support Mr.Dhaya devadas by writing false information aboutother producers. We explain the facts to the media group or editors and they warn Sandhya. She jumps to the next one and tries the same. This is a cycle. Suddenly one day she started accusing us of threatening (without any proof of course) and wewanted to learn why. On asking around, we found that, she doesn’t have a good reputation inthe press club for she was taking sides in their election process and many senior journalistdidn’t like that. When entire TN was supporting Jallikattu festival, she was openly commentingagainst it when staunch TN social media users trolled her. She conveniently played the victimcard accusing that against us. Jallikattu or her press club issue has nothing for us and we haveno affair to intervene or comment her role. Some random comments made in social media byrandom guy has to do with us? She hasn’t done any legal stories to support her, so she has tothrive by playing victim card against beach mineral industry. Even the videos of her meeting the so-called source was widely spread in social media (even areputed whistle blower Savukku published it in his timeline). He claimed Sandya was visitingEx-DGP to misguide DMK using his closeness to DMK. So that also was blamed on us. In factsomeone in social media picked up the video from social media and sent to us saying Sandhyawas meeting to conspire against us. We can only ignore such things. Please apply some logic my friend and provide us a concrete proof so that we have somethingto answer to. But I must tell you, it is a big nexus in which Sandya is involved in and they have the habit ofpublishing a story every time a court hearing for this beach mineral case comes to court. Theirintention is only to cause pre-judice against us in the minds of the judges, so that justice can bedelayed. I too came across a blog maintained supposedly by one of our well wisherhttp://vetri3337.blogspot.in/. You can find lot of information about SandhyaRavishankar. Also please ask your so-called sources, friends of Sandya or even Sandya whythey conveniently forgot to talk to Daya devadas or their illegal mining in 2011. I am sure she

http://o.s.no/

http://vetri3337.blogspot.in/



never disclosed the fact that her husband was denied an opportunity in our group. Withpersonal enmity and history in the past, do you think she will give a fair opinion on us? You arebeing used to fulfil her vengeance. Please take a clear call. I hope your story will be based on the above said points. As promised, please publish our sidereply also. I still count you will do fairness to your journalism which is the fourth pillar ofdemocracy. Any deviation from my reply or misrepresentation will only push us to take legalrecourse. I represent my company as a spokes person, so if you are carrying any person’s name in theinterview, you can only use my name. The company is owned by multiple partners and wedon’t want to be tagged with one particular directors / partners.

Once again I kindly urge you to dig more about the personal enmity Sandya Ravishankar haswith us, ever since her husband was denied an opportunity. Consider the fact that she doesn’tspell a word about her friend Daya devadas. The way she is using sand mining to deceive youabout Heavy mineral mining, the way she generically refers to us as violators especially whenreports like Sahoo report specifically confirmed we are acting as per law. All this will clearly sayhow biased Sandya Ravishankar is. She is not a crusader against illegal mining like how sheclaims she is. In fact, if she has to talk to illegal mining she has to talk about widespread illegalriver sand mining, or iron ore mining or coal mining or Daya devadas illegal mining. Howconvenient it is to work with an agenda? I believe you or the media you are associated with arenot working with an agenda and you will study those documents and take a learned decision.

With Best Regards

Sakthiganapathy.C

Manager

Anx 3.pdf

Anx -4.pdf

Anx -8.pdf

Anx-1.mp4

Anx-2.pdf

Anx-5.pdf

Anx-6.pdf

Anx-7.pdf

Anx-9 - Copy.pdf

Anx-9.pdf

Anx-10 -1 - Copy.jpg

Anx-10 -1.jpg

Anx-10 -2 - Copy.png

Anx-10 -2.png

Anx-10-3 - Copy.png

Anx-10-3.png

https://drive.google.com/a/vvgroup.biz/file/d/1s1WGh3_NoQi4O2-ZMHTg-183sJjEBEax/view?usp=drive_web

https://drive.google.com/a/vvgroup.biz/file/d/1Te8nq4sdoP63PiowU1KGM3chpQrMLdWb/view?usp=drive_web

https://drive.google.com/a/vvgroup.biz/file/d/1AkWUiTMCE8_G6TxYKttHZUFFje-ddix3/view?usp=drive_web

https://drive.google.com/a/vvgroup.biz/file/d/1I-Ia74n4802rG29gFpVioBoEOM99eRE8/view?usp=drive_web

https://drive.google.com/a/vvgroup.biz/file/d/119H5s6NY3YguIafjL0yTd3hT7aXilKMX/view?usp=drive_web

https://drive.google.com/a/vvgroup.biz/file/d/1P8B2fz7H8Edw4y6msoQlG_YyEpGjv_a-/view?usp=drive_web

https://drive.google.com/a/vvgroup.biz/file/d/1ofLyHhsIKux5qSw0GTRJSlFlDZMM8CWF/view?usp=drive_web

https://drive.google.com/a/vvgroup.biz/file/d/1NsJlhRttkcC7lmOStd8Jn8gbzGOad_kV/view?usp=drive_web

https://drive.google.com/a/vvgroup.biz/file/d/13zPibgkl4h4VwSu9jiyh2uvm8NwcyyUx/view?usp=drive_web

https://drive.google.com/a/vvgroup.biz/file/d/1PRiXGwxsTJpJzDRJI2BTyjk-IPOb4mYh/view?usp=drive_web

https://drive.google.com/a/vvgroup.biz/file/d/1y-O3X1SONa2BQqFy7_hZGB9x4_ooYd2B/view?usp=drive_web

https://drive.google.com/a/vvgroup.biz/file/d/191n6qg2aWUCO1iuci4eWqcnb1TZY7TOq/view?usp=drive_web

https://drive.google.com/a/vvgroup.biz/file/d/13STHxlq9e_2ZzQAHQVJ1Tfmvf_eNiyo8/view?usp=drive_web

https://drive.google.com/a/vvgroup.biz/file/d/13YK9k7S-rfH1BAp9MMAoPYlZtfOSLaxg/view?usp=drive_web

https://drive.google.com/a/vvgroup.biz/file/d/1AZFfBeobgB_tX5aLN4yElCctQym6_N7t/view?usp=drive_web

https://drive.google.com/a/vvgroup.biz/file/d/1wZTWF4YHC-HJJZW8PozDlkSuYo-xJ594/view?usp=drive_web



Anx-11.pdf

Anx-12.mov

https://drive.google.com/a/vvgroup.biz/file/d/1aZXY-8OzUdZhP_gGGu7ZJfCinuFcOwFy/view?usp=drive_web

https://drive.google.com/a/vvgroup.biz/file/d/15VjclL95IqWoOt9imNhxH_nEYPRVqfMS/view?usp=drive_web