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JUDICIAL AFFIDAVIT
OF
BRYAN O. ESPINOLA
A) All the allegations in the Collection for Sum of Money including all annexes
appended thereto;
B) All other related matters, facts and circumstances relevant and material to this
case.
This Judicial Affidavit was taken at the office of Atty. Warlito Ebarle Labis at
4A Macrohon Building, Campaner Street, Antipolo
Questions were propounded by Atty. Warlito E. Labis and these questions are
numbered consecutively and each question is followed by the answer of the
witness.
1. Q: Do you swear to tell the truth and nothing but the truth?
A: I do.
2. Q: Are you aware that you may face criminal liability for false testimony or
perjury if you will not tell the truth?
A: I am.
4. Q: Are you the same Liaison Officer working for ABC Trading Inc.?
5. Q: Do you know the Respondent in this case, Bella, Cathy, & Donna
Partnership?
7. Q: Can you tell us in detail when your company instructed you to send those
demand letters and when the respondent received the same?
A: I sent the first demand letter on March 18, 2019 and it was received on
March 20, 2019. The second demand letter was sent on June 17, 2019 and it was
likewise received by the respondent on June 21, 2019. The third demand letter was
sent on September 6, 2019 and received the same on September 10, 2019. The
fourth demand letter was sent on December 23, 2019 and likewise received by the
respondent on December 27, 2019. The last demand letter from our company was
sent last January 6, 2020 and likewise received by the respondents last January 7,
2020.
Affiant further sayeth naught.
I hereby state, under oath, that I faithfully recorded the questions I asked and
the corresponding answers that the witness gave and that neither I nor any other
person present or assisting me has coached the witness regarding the latter’s
statement.
Copy furnished:
Office of the City Public Prosecutor
Antipolo City