Director Deputy FIA Cyber Crime Dated: 20.07.2019

Subject: COMPLAINT & SUBMISSION OF PROOF ON BEHALF OF MR. EVIDENCING THE PERSONAL VENDETTA OF CERTAIN INDIVIDUALS TO MALIGN HIM ON SOCIAL/PRINT MEDIA IN APPARENT VIOLATION OF THE PREVENTION OF ELECTRONIC CRIMES ACT, 2016 (“ the 2016 Act”)

It is respectfully submitted that:

1. The Complainant, Mr. Ali Zafar, is a renowned celebrity and an internationally acclaimed artist and as part of the performing industry he is heavily reliant on his professional and personal reputation. He is recipient of numerous national and international awards and is a respectable, law abiding and responsible member of the society. He has a huge fan following out of which many consider him as their idol. The fame that he has received in and worldwide is the result of years of hard work. The Complainant strictly believes in the highest of professional standards.

2. It is pertinent to note that the Complainant, despite having been in the entertainment industry for over 20 years, has never been faced with an organized attempt to tear down his public image by spreading untrue and false information about his character or demeanor towards women.

3. Only recently, he has been made a target of a severely misleading social media campaign which attempts to accuse and portray Complainant as a sexual predator, and has disseminated to the public-at-large phony stories of Complainant’s conduct. The said campaign has now continued for over a year now which has multiplied in magnitude and caused Complainant and his family irreparable emotional, psychological and financial harm.

4. If the record as reproduced herein is perused, it becomes apparent that the social media accounts are part of a systemized and collective effort to defame and damage Complainant’s reputation and livelihood by continually posting derogatory, insulting, inciting and insinuating remarks against the Complainant and his character on various social media forums such as , Instagram and Facebook. The language used in such posts/comments

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is extremely vulgar evidencing the ulterior motives of certain individuals to malign Complainant to the extent of public shame.

5. To the best of Complainant’s knowledge, this campaign had taken root from a comment posted on Complainant’s Manager, Taha Sadaqat’s social media account on Instagram on 02.02.2018. A user by the name of ‘sana_samir_91’ made the following threatening comment: "And I must say you are going to have a lot of work on your hands when we all take your pervert client to the cleaners close to his movie release. Enjoy"1. The aforesaid comment visibly demonstrates that perpetrators of this social media campaign had at a very strategic time – release of Complainant’s anticipated film – decided to smear his reputation. This was followed by appearances of other such fake accounts, such as nehasaigol1, that carried on a planned narrative of threatening and labeling Complainant as a harasser and pervert.

6. On 19.04.2018 Ms. , to further the cause of the baseless campaign, made patently false and bald allegations on Twitter against the Complainant alleging sexual harassment. Her first tweet did not contain any details of the incident but on 21.04.2018 in an interview published in the ‘InStep Today’ (The News) Ms. Meesha Shafi claimed to have been sexually harassed by the Complainant twice. Again, no further details were given of the alleged first incident but in respect of the alleged second incident it was claimed to have taken place during a jamming session at Lahore. However, on 23.06.2018 the Complainant categorically denied said allegations as being patently false and announced to pursue his legal remedies against Ms. Meesha Shafi for defamation. On 23.06.2018, the Complainant instituted a suit against Ms. Shafi before the learned District Judge, Lahore wherein vide Order dated 23.06.2018 the learned Court restrained Ms. Shafi from making any derogatory remarks against the Complainant. The case is pending adjudication.

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7. In response to the defamation suit, Ms. Shafi discreetly preferred a complaint against the Complainant before the Federal Ombudsman for Protection against Harassment of Women at Workplace which was subsequently dismissed.

8. Notwithstanding the dismissal of Ms. Shafi’s complaint by the Federal Ombudsman, her sympathizers and accomplices continued to make derogatory remarks against the Complainant, his family and colleagues in an extensive social media campaign, in direct contradiction to the injunctive order dated 23.06.2018 and provisions of the 2016 Act. It is rather critical to note that the narrative used to defame him was repeatedly endorsed and propagated with the help of a number of fake accounts and few bloggers. The said accounts have collectively managed to post thousands of tweets against the Complainant while tagging important people and publications. Moreover, many tweets posted by such accounts were then quoted in prominent and credible national and international publications. It is also noteworthy that few prominent journalists have also been a part this false narrative sketched out against the Complainant.

9. Given that social media has been abused from the very outset to spread false information about the Complainant causing intimidation, loss of reputation, and invasion of privacy, the same amounts to a clear violation of Section 20 and Section 25 of the 2016 Act. In view of above it is imperative that FIA not only investigates violations of the 2016 Act, but also seeks to protect the victim i.e. the Complainant of this smear campaign from being harassed online by taking down such abusive and defamatory social media posts, comments, pages and accounts. An account of the false propaganda against Complainant on social media is appended herewith for your kind perusal.

10. It is hereby conferred that Ms. Shafi’s Lawyer Ms. Nighat Dad is a common connection with other women and a fake account “Neha Saigol1” that made false allegations against Mr. Zafar and were a part of the smear campaign against him. Most of these women or people involved in smear campaign are associated directly or indirectly with Ms. Nighat Dad or her NGO, the Digital Rights Foundation that claims to work for on line digital rights, however is working in conflict with its own mandate.

11. In light of the above, serious action should be taken against the following accounts:

i. Meesha Shafi (Artist) https://twitter.com/itsmeeshashafi

ii. Nighat Dad (Meesha's Lawyer) https://twitter.com/nighatdad

iii. Leena Ghani (Make Up Artist & Painter) https://twitter.com/Leena_Ghani

iv. Hamna Zubair (Journalist -)

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https://twitter.com/hamnazubair

v. Manal Faheem (Journalist - Cutacut.com) https://twitter.com/ManalFaheemKhan

vi. Sephora https://twitter.com/seraphina444

vii. Iffat Omar (Artist) https://web.facebook.com/iffat.umar.1

viii. Ali Gul Pir (Artist) https://twitter.com/Aligulpir

ix. Maham Javed (Journalist- NayaDur) https://twitter.com/JMaham

x. Jami Azad (Director) https://twitter.com/jamiazaad

xi. Hamna Raza (Blogger) https://twitter.com/HumnaRaza

xii. PaxFemina (Blogger) https://twitter.com/PaxFemina

xiii. Fariha Awan (Blogger) https://twitter.com/Fay_Alif

xiv. Haseem Uz Zaman (Blogger) https://twitter.com/haseemuzzaman

xv. Faizan (Blogger) https://twitter.com/merabichrayaar

xvi. Mohsin Sayeed (Journalist) https://web.facebook.com/mohsin.sayeed.9

12. FIA is also requested to take prompt and serious action against the following fake accounts:

xvii. Neha Saigol https://twitter.com/nehasaigol1

xviii. Mehar Hareem (Admin of “Support Meesha Group” on Facebook) 4

https://twitter.com/MeharHareem https://www.facebook.com/hareem.mehar.7370 https://www.instagram.com/hareemmehar017/ https://www.facebook.com/groups/supportmeeshashafi/

xix. PkPopCulture https://twitter.com/pkpopculture

xx. Sana_Samir_91 https://www.instagram.com/sana_samir_91/

xxi. Sallzjay22 https://www.instagram.com/sallzjay22

xxii. SaadiaFarooq (Admin of “Support Meesha Group”)

xxiii. ZainabJamil (Admin of “Support Meesha Group”)

xxiv. Sania Sheikh https://twitter.com/saniash34490923

xxv. RidaHaroon https://twitter.com/ridaharoon3

xxvi. Alia Sharif (Admin of “Support Meesha Group”) https://twitter.com/AliaSharif13 https://www.facebook.com/AliaSharifOfficial212

xxvii. Deenz82 https://www.instagram.com/deeenz82

xxviii. Raisa Chaudhry https://web.facebook.com/100005002113577

It is therefore requested that FIA takes decisive action to prevent dissemination of such false information on social media which has affected Complainant’s reputation and emotional well- being.

Looking forward to a positive outcome in this regard.

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COMPLAINANT

Through:

Muhammad Ali Raza Advocate Supreme Court

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[PART-I]

INDIVIDUALS WHO HAVE COLLUDED TO FALSELY ACCUSE MR.ALI ZAFAR AND THEIR CONNECTION

MEESHA SHAFI – ARTIST

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 Meesha Shafi, who has been friends with Ali Zafar and his wife Ayesha Fazli since many years, accused Ali Zafar of sexual harassment on Twitter at 3:45 pm claiming that he had harassed her several times over the years.

 This statement is directly in contradiction to Meesha Shafi’s social media accounts - Twitter, Facebook and Instagram – wherein she has posted pictures with Ali Zafar on numerous occasions. Some of these pictures are attached below.

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 This picture was posted by Meesha Shafi on her Twitter account after her latest performance with Ali Zafar. However, the same was discretely deleted a few days before she made the accusation.

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 This picture was posted by Meesha Shafi during 2016 where she captions the picture with “These smiles are real” standing alongside Ali Zafar.

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 This picture was posted by Meesha Shafi on her personal Facebook profile taken at Ayesha Fazli’s birthday party. It is pertinent to note that in her reply to Ali Zafar's defamation suit against her, she quotes that one of the incidents where she was harassed was at Ali Zafar’s wife Ayesha Fazli’s birthday party.

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 Thereafter, she posts another picture from the same birthday party on her Instagram giving photo credit to her “alleged” harasser Ali Zafar.

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 She then continues to post pictures with her “alleged” harasser on her social media without any qualms.

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‘MEESHA SHAFI’S MESSAGE’ THANKING ALI ZAFAR AFTER ALLEGED HARASSMENT

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NIGHAT DAD – MEESHA SHAFI’S LAWYER AND AN ADVOCATE OF DIGITAL AND PRIVACY RIGHTS IS HERSELF INVOLVED IN DEFAMING AND CYBER BULLYING MR. ALI ZAFAR.

Link: https://twitter.com/nighatdad/status/986936815444725760

Link: https://twitter.com/nighatdad/status/987387805486796800

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NIGHAT DAD CONNECTION WITH MEESHA SHAFI They started to exchange messages on twitter 11 months before accusation. LINK: https://twitter.com/nighatdad/status/865267506717577216

LINK: https://twitter.com/itsmeeshashafi/status/867412454472642561

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LINK: https://twitter.com/itsmeeshashafi/status/909311158041157632

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LINK: https://twitter.com/nighatdad/status/979173475129659392

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On 19th April 2018, after Meesha Shafi posted a false and malicious accusation against Ali Zafar on her twitter account, an article written by Ms. Hamna Zubair titled 'Meesha Shafi accuses Ali Zafar of sexual harassment, encourages women to break ‘culture of silence’' was published on 'Dawn Images' at 3:56, 11 minutes after Meesha’s accusation, without publishing Ali Zafar's side of story.

Ms. Hamna Zubair has been actively involved in smear campaign against Mr. Zafar since Ms Shafi’s allegation against all ethics of journalism. As editor of Dawn Images, Miss Hamna Zubair not only used her personal twitter account but also Dawn’s platform to post and publish various defamatory and derogatory remarks and articles against Mr Zafar including his film . She was also a part of the protests against his film on the day of the premier in . Evidence regarding the same is in Part II of this file on page 68.

Link: https://twitter.com/dawn_images/status/986921582592516097

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After 6 minutes of publication, same article was retweeted by Ms. Nighat Dad with her tweet inviting more women to come forward

Link: https://twitter.com/nighatdad/status/986922929014411271

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At 10:05 pm, a blogger/journalist named Maham Javaid made the following tweet, which within minutes was soon replied by Nighat Dad.

 The claims made my Maham Javaid have been uncorroborated.

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Following is the evidence of Maham Javed’s connection with Nighat Dad and her NGO prior to these allegations.

Ms. Maham Javaid is closely associated with Ms. Nighat Dad, she has been working with her NGO digital rights foundation and writing in her favor since 2017

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(Page 01/02)

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(Page 02/02)

Nighat Dad communication on Maham Javaid’s profile on 8th March, 2018.

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MAHAM JAVAID WROTE AN ARTICLE AFTER ATTENDING AURAT MARCH ON THE NEWS SUNDAY ON MARCH 11, 2018. IN NEWS COVER, LEENA GHANI AND NIGHAT DAD CAN BE SPOTTED TOGETHER.

Link: thenews.com.pk/tns/detail/565123-paratha- rolls-gender-roles

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At 11:53 PM Leena Ghani’s posted a false Allegation on Ali Zafar

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Following is the evidence of Leena Ghani’s connection with Nighat Dad prior to these false allegations.

Leena Ghani and Nighat Dad were spotted together at Aurat March 2018, 40 days before allegation on Ali Zafar, which shows their association for a common agenda.

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Link: https://twitter.com/Leena_Ghani/status/979414269799354368

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Link: https://twitter.com/Leena_Ghani/status/983964842892713984

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Leena Ghani spotted with Meesha’s lawyer on after Aurat March 2019 in Lahore

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LEENA GHANI – Makeup Artist/Painter/Co-organizer of Aurat March. Meesha Shafi and Leena Ghani are not only old friends but have also graduated from the same college – .

Leena Ghani posted this picture of Meesha Shafi on her Instagram account on 31st March 2015 where she did her make up a shoot for a magazine Hello Pakistan.

Link: https://www.instagram.com/p/05Tk3PSK_z

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Leena Ghani and Meesha Shafi were spotted together at Aurat March 2019, shows their association for a common agenda.

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Fariha Awan - Blogger

On May 05, 2019 a blogger Fariha Awan falsely alleged Ali Zafar on twitter of harassing more than 5 girls at his A-levels institute. Though, he did FA from a Government college

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Following is the evidence of Fariha Awan connection with Nighat Dad prior to these allegations.

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An activist and lawyer tweeted about how Ms. Nighat Dad deleted the audit report of her NGO from her website alleging her “misusing the #metoo movement” demanding an audit.

Link: https://twitter.com/HniaziISF/status/1147540910068183050

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On May 3, 2016, Khadija was attacked by her class fellow Shah Hussain. In an article published by cfr.org, Nighat Dad claimed that she fought Khadija's case which was soon called out by Khadija herself in a Tweet. Later, due to social media backlash the very same article was revised.

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HAMNA RAZA – Blogger

At 8:17 pm a blogger Hamna Raza tagged Faizan (merabichrayaar) and tweeted:

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CONNECTION OF HUMNA RAZA & FAIZAN (merabichrayaar)

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1. Sephora, previously on social media as Sofi

 Sephora falsely accused Ali Zafar on the same day Twitter Link as Meesha Shafi in the tweet below. However, the https://twitter.com/seraphin said tweet was deleted after Ms. Naila Khan, the a444 official representative of Shaukat Khanum, disapproved her claims.

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IFFAT UMAR – Artist

Link: https://web.facebook.com/iffat.umar.1

Actor Iffat Umar has been actively involved in defaming Ali Zafar maliciously. She is closely related to Meesha Shafi’s mother actor Saba Hameed.

(Source: Nangay Paon)

SABA HAMID IFFAT OMAR

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Picture of Saba Hamid & Nighat Dad

Iffat Umar’s derogatory remarks on social media against Ali Zafar

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ALI GUL PIR – Artist

Ali Gul Pir is a rapper and stand-up comedian, posted derogatory remark and directly alleged Ali Zafar on Twitter.

https://twitter.com/Aligulpir/status/1104245972740263936

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Link: https://twitter.com/Aligulpir/status/1129252030298632192

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FAIZAN – Blogger

Faizan is a blogger and social media influencer, posted various alleging and defamatory tweets against Ali Zafar.

Link: https://twitter.com/merabichrayaar

https://twitter.com/merabichrayaar/status/1073116799774924800

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https://twitter.com/merabichrayaar/status/1123181962150195200

https://twitter.com/merabichrayaar/status/1112003209273335808

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Haseem Uz Zaman – Blogger

Haseem Uz Zaman is a blogger and a news editor, directly alleged Ali Zafar and posted defamatory tweets against Ali Zafar.

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JAMI AZAAD (Director)

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MOHSIN SAYEED (Journalist)

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[PART-II]

VALIDATION OF FAKE ACCOUNT(S) THROUGH DIFFERENT CHANNELS BY THE HELP OF EDITORS AND BLOGGERS

1. Hamna Zubair – Editor Dawn News

Twitter Link: https://twitter.com/hamnazubair

DEFAMATORY TWEETS OF HAMNA ZUBAIR AGAINST ALI ZAFAR

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Also the screen shot of a story posted on Dawn Image’s Instagram under Hamna Zubair lying about the red carpet of Teefa in Trouble being empty.

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HAMNA ZUBAIR CONNECTION WITH NIGHAT DAD

Hamna Zubair has previously been the part of Nighat Dad’s NGO and have been in touch with her since 2016.

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Manal Faheem Khan – Editor Cutacut

 Twitter Link: https://twitter.com/manalfaheemkhan

Link: https://cutacut.com/2018/06/22/opinion -why-ill-be-boycotting-ali-zafars-teefa- in-trouble/

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Link: https://cutacut.com/2019/01/19/ the-best-thing-about-this-years- psl-anthem-no-more-ali- zafar/06/22/opinion-why-ill-be- boycotting-ali-zafars-teefa-in- trouble/

Link: https://twitter.com/ManalFaheemKh an/status/1114489516012855296

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Link: https://twitter.com/ManalFaheemKhan/ status/1073244277583556608

Link: https://twitter.com/ManalFaheemKhan /status/1100467825884434432

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MANAL REPLYING TO ANOTHER FAKE ACCOUNT.

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Pax Femina

 Twitter Link: https://twitter.com/PaxFemina

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2. Meesha's Legal Counsel Barrister Ahmed Panosta was also involved in posting derogatory tweets against Ali Zafar, against all legal ethics.

 Twitter Link: https://twitter.com/ Pansota1

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DEROGATORY AND DEFAMATORY ARTICLES AGAINST ALI ZAFAR PUBLISHED ON WEBSITE

WEBSITES & PUBLICATIONS USED TO PROMOTE FAKE PROFILES. https://gulfnews.com/world/asia/pakistan/pakistani-actress-model-meesha-shafis- sexual-harassment- appeal-against-actor-ali-zafar-dismissed-1.2260345 http://www.socialpakistan.pk/siasi-videos/the-governor-of-punjab-rejected- meesha-shafis-case-and- people-are-just-disappointed/ https://hnow.tv/blog/punjab-governor-dismisses-meesha-shafis-sexual-harassment-case/

CUTACUT https://cutacut.com/2019/04/01/lux-style-awards-2019-stir-controversy-by- nominating-ali-zafar-amid- sexual-harassment-accusations/ https://cutacut.com/2018/06/22/opinion-why-ill-be-boycotting-ali- zafars-teefa-in-trouble/ https://cutacut.com/2019/01/19/the-best- thing-about-this-years-psl-anthem-no-more-ali-zafar/ https://cutacut.com/2018/05/12/legally-speaking-whats-next-for- meesha-shafi-and-ali-zafar/ https://cutacut.com/2018/05/07/another-woman-comes-forward-with-sexual- harassment-allegations-against- ali-zafar/ https://cutacut.com/2018/05/18/how-many-women-will-it-take-meesha-shafi/

NAYADAUR https://nayadaur.tv/2019/03/backlash-over-ali-zafar- nomination-of-best-actor/ https://nayadaur.tv/2019/03/backlash-over-ali-zafar-nomination-of-best-actor/

DAWN NEWS https://images.dawn.com/news/1180390 https://images.dawn.com/news/1179895 https://www.dawn.com/news/1439810 https://www.dawn.com/news/1425530 https://images.dawn.com/news/1182233

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PARHLO https://www.parhlo.com/hamza-ali-speaks-on-ali-meesha-controversy/ https://www.parhlo.com/the-way-pakistanis-have-reacted-to-ali-meesha-case-is-totally- surprising/

MANGOBAAZ https://www.mangobaaz.com/ali-zafar-sexiest-pakistani-man-pissed https://www.mangobaaz.com/ali-zafar-sexual-harassment https://www.mangobaaz.com/sexual-harassment-how-not-to-react

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Link: https://www.mangobaaz.com/ali-zafar-sexual-harassment

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[PART-III]

LIST OF FAKE PROFILES BEING USED TO FUEL THE PROPOGANDA AGAINST MR.ALI ZAFAR

1. Neha Saigol

 Account of Neha Saigol was made on Twitter on 1st March 2018, 50 days before allegation on Ali Zafar. Till to date, this account has tweeted more than 3000 times against Ali Zafar.

 The first six followers on this account are purportedly connected to Meesha Shafi as seen below. 1st Follower: Bushra Hamid (Meesha’s Aunt) 3rd Follower: Saba Hamid (Meesha’s Mother) 4th Follower: Leena Ghani (Meesha’s Friend) 6th Follower: Nighat Dad (Meesha’s Lawyer)

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 Tweets on this account prior to Meesha Shafi’s allegation.

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2. Mehar Hareem

 Twitter Link:https://twitter.com/MeharHareem  Facebook Link: https://www.facebook.com/hareem.mehar.7370  Instagram Link: https://www.instagram.com/hareemmehar017/  Link of Facebook Group: https://www.facebook.com/groups/supportmeeshashafi/

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ALL SIX PROFILES WHICH ARE APPARENTLY THE ADMINS/MODERATORS ARE FAKE. THESE FAKE ACCOUNTS ARE FURTHER LINKED WITH TWITTER & INSTAGRAM TO PROMOTE ABUSIVE AND DEFAMATORY CONTENT AGAINST ALI ZAFAR

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3. PkpopCulture

 Twitter Link: https://twitter.com/pkpopculture

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4. Sania Sheikh Twitter Link: https://twitter.com/saniash34490923

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5. Rida Haroon  Twitter Link: https://twitter.com/ridaharoon3

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6. Alia Sharif

 Twitter Link: https://twitter.com/AliaSharif13  Facebook Link: https://www.facebook.com/AliaSharifOfficial212  Moderator of Facebook Group with Mehar Hassan https://www.facebook.com/groups/supportmeeshashafi/

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7. Deeenz82

 Instagram Link: https://www.instagram.com/deeenz82

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8. Sana Samir

 Instagram Link: https://www.instagram.com/sana_samir_91/

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9. Sallzjay22

 Instagram Link: https://www.instagram.com/sallzjay22/

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