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Pedro Ramirez Affidavit (part 2) Graft and Corruption
1. Republic of the philippines)
Cityof Maniia .... .) SS
APFIDAVIT.COMPLAINT
I,
PEDRO D. RAMIREZ, JR., of legal
sge, Filipino, and resident of
Pagadian City, after being duly sworn
to in accordance with law, hereby depose
and say: That-
THE COMPLAINANT
' 1' I was appointed as Assistant
Provincial Treasure r of zarnboanga del
sur gn April 2oo2 and designated as oIC provincial
15 ,
2072', vice Filomena B. pongon, up Treasurer on May 2,
to the present time;
2' I may be served with notices, orders and resolution
Purok Pag-Asa, Sto. Nino District, pagadian at my address at
City
THE RESFONDENTS
3' Antonio H' cerilles is the incumbent provinciai
zamboanga del Sur' Governor of
,l ^A.urora E. cerilles was the provincial Governor
Zamboanga del Sur during the period of
2oo1, to 2olo, and is now the
ryil Representative of the province,s 2ao District;
4' Fo' PurPoses of service of legal processes, Antonio H. cerilles and
Au'ora E' cerilles may be served with notic.s,
ord"ers and resolution, at their
official residence in sumadat, Dumalinao,
zarnboanga der sur, although, they
actually reside at canuto Enerio street, sto.
Nino, pagadian city;
ALLEGATIONS OF CzuMINAL ACTS
5' when I was appointed in 2ao2, the Provincial
Aurora E' ceriltes who is now the Rep:resentative Governor then was
of the 2,a Legislative District
of zarnbaanga del sur. After the enc of her third
husband Antonio H' cerilles became the Provincial
term in ]une 2o10, her
Governor. He used. to be
the Representativ,-: of the 2"d Legislative
District;
6' As the oIC Provincial rreasurer, I am in charge in
taxes' fees and charges, and monies for the provincial the collection of
Zamboanga del Sur, and the disbursement Government of
of government funds for the
payment of provincial obrigation to craimants,
suppliers, contractors, etc.;
7' ln addition to my d.uties and responsibilities as oic provincial
Treasurer' I was also designated by the Provincial Governor
as member of the
Page L of 1!.
Affidavit of pedro CI. Ranlirez, Jr.
2. Bids and Awards committee (BAC). I
am also a mernber of the Locai Finance
Cornmittee and pi:.ovincial Appraisa-l Committee;
8'
since I assumed office, I have not been fully
and freely performing my
tasks as oIC Provincial Treasurer as these were
restricted and controlled by
then Governor Aurora cerilies and tr"ater continued
by Governor Antonio
cerilles' In fact, even during the three terms of then Governor
Aurora ceritrtres,
her husband then Rep. Antonio Cerilles activeiy interfered
provinciai government, especialty on the finances;
in the affairs of the
9' I could not do otherwise but to follow all the instructions
of the cerilles couple for fear of loss of my employment and orriers
ana ev* of roy iife. The
cerilles coupie wield immense pcwer aerd influence in the province.
power and influence are not limited cver the And rheir-
rank and fiie of the provir:cial
Goverrnment but extend to the officiais and personnel
of the different national
agencies, inclur ;rg the Philippine National police,
National Bureau cf
investigation ano Phiiippine Drug Enforcement
Agency, by reason of their
strong connection with former President Gloria
Macapagal-Arroyo and her
cabinet members. Although somewhar diminished,
they still hoid power and
influence under the ad'ministration of Pr:esident Noynoy
Aquino. They use tlreir
weaith effectively to rnaintain and expand their influence;
Absolute and Exclttsiue Control Of t-und.s;
I Ereakdawn of the Internal Contral;
ru{ 10' Then Governor Aurora cerilles and later Governor Antonio
cerilles
absoluteiy and exclusively control the disbursement of
funds of the provi*cial
Government. They dictate who gets paid first and for how
much. No check is
prepared with<lut the directive of the governor. They
even sign the checks
ahead of me! I have become a counter-signatory. sometimes,
they aiso pre-
sign the disburseroent vouchers. such is the reversal of
roles in the processing
of the disbursement vouchers anc the issuance of the
checks in the provincial
Government' The affixing of my signature, as well as that
of the provincial
Accountant, has become "rninisterial" and "mechanical,
Everything is controlled and dictated by the cerilles coupie.
on olrr part.
Attached,, as
Annex uA" to Annex uJ', are pictures of checks and disbursement
vouchers pre-
signed by Governor Antonio Ceritrles antl made an integratr part
hereof;
1 1' Thus the established ccntrols as provided for in the Ne-*r
Government Accounting system (NGAS), in the provincial
tsudget office,
Provincial Accounting office and Provincial rreasurer's
office in the processing
of the riisbursement vouchers are totaltry disregarded. There is
no prio::
determination whether the expend,iture is necessa-ry and trawful,
and ccverec by
all atr]propriation and aliotroent; whether the aliotment has been
obligateri an.d
the expenditure has supporting documents; and whether funds
are a'aiiai:le.
Thus, accounts were paid even without appropriations, checks
were issued
Page ? of 11
Affldavlt of Fedno D. Ramireu, Jr.
3. even without the covering disbursement vouchers
and supporting documents,
and sometimes checks even bounced;
Checks Withowt Disbursernent Vouchers
And Suppor-ting Doqiments
12' During the years 2008 and 2oo9, then Governor Aurora cerilles
ordered me to prepare checks even without the covering
disbursement
vouchers and supporting documents. initially, I refused
and ad.vised her that it
was illegai' The cashier trikewise refused. tsut Governor
persisted and pressured us to follow her order'.
Aurora cerilles
Fearing that i may"lose my
employment {she had strong influence in the Department
of Finance during the
Arroyo Administration) and physicar harm might befali
reluctantly
on my person, i
acceded to her order;
13' Fortunately, the coA diseovered the anomaly during the
reguiar
annual audit of the books of accounrs for the years 2008 and 2o0g.
warning of CoA to me and Provincial Accountant ordonez The stern
for-ced then
Governor Aurora cerilles to stop the iilegal practice
which I could not have
otherwise prevented. trn its audit for the y.rru 2009 (Audit
I Finding No. i) and
2008 (Audit Finding lrtro. 1), the CoA dis.covered that checks
in the total amount
of P 57,12O,197'24 and P 16,053,L34.4a, respectively, were
issued in the said
d years. The COA Audit Reports state as follows:
2O09 Auciit Report
L. Check paymoute in the total amount of F5?,LA0,1S?"?4
crere not supported. with dutry approved Diebuu,sernemt
vouchers, contrary to sound internar contror p*licies,
ca*si,ug doubt on the varldity and regatity of the
transaations, accureelr of the escount balances, ieategri*y ef
the accounting and eash records, reakiag the reopeative
asset and expenae &ceounts overstated.
2O08 Audit Report
1. claims without dury approved vouchers totaring
P16,CI53rt 34.40 were taken up 6,a prepaid e*Ile*&es,
contraqr to existiag rules and reguxatlons, reeuliing to
qrverstatement of, aseets and uuderstatemest
{3fl
corresponding aeset or expellse accoqlrtte.
The above audit findings were one of the reasons for the issuance
o{ an
ADVERStr oPINIoIri of the coA on th.: {inancial statements of provincial.
the
Governrnent for the years 2O0g and 2OOg;
Page 3 of lt
,&ffidavit of Pedro D. Rarnirez,Ir.
4. 14' The checks issued in 2oag, without the covering
disbursemenr
vouchers and supporting documents, urere mostly payable
to favored suppiiers,
Lucky saver Geni'ral Merchandise and Botica JiIl
both ownec by LizaAranding
u'ho is a relative of Governor Aurora cerilles. The
said L;;;;;"ding is also a
big financier of the ceriiles couple during eiections.
A copy of
checks Issued without supporting Dotuments, consisting the coA List of
attached as Annex "r{" to Annex "K*s" and made
of six pages is
an integral part hereof;
Illegal Disbwrsement of Trust Rtnd.s
15' with the absoiute control of the cerilles coupie over the firiances
the Provinciai Government, the provincial funds are being of
spent illegaily,
wastefully; whimsically and uncontroliably. It was not surprising
that tirrre anc
again the General Fund became depleted. when this
happened, the cerilies
coupie (then Governor Aurora cerilles during her
three terms and incumbent
Governor Antonio Ceriiles) ordered me to transfer
the funds from the Trust
F''und to the General Fund' when I objected and
explained to them that Trust
Funds could only be spent for the specific purpose for
1 which it was createc cr
received, they further pressured me until I reluctantly
acceded,;
I
16' Expectediy, the CoA d.i.scovered the aforementionec illega-l
t$ tr disbursements in its annual audit in the years 2011 (Audit
ti
iI 2o1o (Audit Finding No. 1 on cash Managementj,2oog (Audit
Finding No. g),
Fincing Nos. 2 &
V 3), and 2aa4 (Audit Finding No. 4). Thus, the coA Audit
Reports state as
follows:
2011 Audit.Rer:ort (During the telrn of Governor Antonio ceriiles)
8. tra&sfer of funds from Trust F.uad to General Fund, speef,e,l
Educatlon E und {sEs.}, and Ecouomic Developmeat $.und,
(EBF'!, vis-r&-vis in the total amouqt of F 43r2ooro6s.ss
wrere
nnade without authority es provided, uqder seqtiorne gos
e,,d &s5 of r€epublic Act {R.A.} ?L6o and $ection s4{2} {b} ef
P.p. L445 thus, the purpose for rs,hie& it was created c&&Erst
be pursued.
2010 Audit Report (During the terms of the cerilles couple)
tr. cash resemred. for trust ftrnds has a uegative belart,ce of p
262,,?.79,715.s4 in vioration of seetioro 4{3} of president{atr
Deeree 1.445, cauoing doubts oa the propriegr and vnlidity
of the transactions alrd the integrity ef the accountirug amd
ce,eh reeords.
Page 4 of lL
Affidavit of Fedro D. Ramirer, Jr.
5. 2' cash pertarniug to truet filnds has a
total amount of p zgraodrgls.a* aegative baxance in tfue
*fro*iog governmerat
fuuds to possible loss andler roisuse, causiag doubts
ore the
propriety and vatridity of the transactions
and the rntegrity
ofthe accounting and cash records.
3. In'tenfu;rd transfers have urEreeorded transactions
7,272,&94.CIO and unreplenished balauce of &"
17'471,833.84 as at year-eud, causing of p
propriety and validity of the trausactior.s
doubts on th.e
and the imtegraty
of the accounting and cash records.
4. Trausfer of funds betweeu differemt projects
Fuud amd between ?rust F.uad to General
within Trusf
s-uud amou&tcd te
P I''281,76s.62 (Aanex '.8,! in violatiqn
of, $ection s4(t! of
FD So. !.jt45.
Intelligence Fwnd
77 '
The Intelligence Fund. is often being used
other than the purpose foi.
which it was created' Heavy withdr awals of
this fund were rnacie during
elections' In April 2010, prior to the IMay 2o1o
elections, then Governor Aurora.
cerilies withdrew the total amount of P3o.0M
in one week, with instructi.on
that the money be in denominations of P100 and p500,
- - ' the withdrawais v,zere
<-v "r'e
made as foilows:
a+ Arnount
Aprii 1"9,201O P 1O,OOO,OOO.OO
April 23, ZOLO 5,000,000.00
April 26,2O1O 15.000.000.00
Total P 30,000.000.aa
Attached, as Annex uL" to oN,, are copies of the
acknowledgernent receipts
signed by Elma Sebuco who counted the money
Governor Aurora Ceriiles;
in the presence of then
18. The audited financial statements of the province
for
2010, 2OAg and 200g would show that tl:e Confidential the years ZAt1,
expenses were used in the 2010 elections. The
and Intelligence
totai expenses for the sairi
years are as follows:
page ti of X.X.
Affidavit of pede,o D. Rarnirez,.!r,
6. Total Expenses
Year
2A11 (a year after the etrections) P 5,105,939.g3
2010 (election year) P 47,642,199.00
2009 (a year before elections) P 22,6A5,513.00
20OB itwo years before elections) P 5,551,440.OO
19' The above figures ctrearly inclicate that the ceiiles
couple used the
confrdential ai:c Intelligence fund.s for political
pllrposes' trn 2008 or two before the elections,campaign and eieciion
total [onficentiai and
Inteliigence expenses r,/as relatively low at p 5,551,44o.oo
only. trt increased i:y
a-bout 450% or iri the amount of p 22,6as,s13.00
in 2009, w,hich ie a 3.ea.i-
before the etrections when the cerilles couple started to prepare
and strengthen
their politicai organization. In the eiection year 2010,
the expenses more than
doubled when the total' confidential and .tntelligence
expenses ::eaci-red.
P47,642,1q9.CIo, and. trso,OoG,Ooo of the saic
amount was withdrarvn in a
week's time (Apnl 79-26,2010). Ttie expense$
substantially tapered cff afier
l the elections, the totai arnounted onry r,, p 6,10s,g3g.g3
I
in 2011;
_.1
l
Canstru ction Maieria'Ls, Afrfice Swpplies,
rf
adffi Gracet'ies Far The Friuate EstabtishrrLerrts
ti/&i
i{ 'ru
And Residence; t*;e of Gouemrment Heaug
Equipment Without Rental, etc.
Il
l 2a' For three consecutive terms of then Governor Auroi-a cer-iiles,
various construction materials, of{ice supplies, grocery
items, etc" -i,vere
withdrawn from favored suppliers and deliverecl to the private
establishrients
owned by the Cerilles couple, inciuding their residence
in Fagadian ciqy. Tirese
materiais were covered by delivery or trust receipts and
duly acknowlecged iry
the workers in the said estabtrishments" These establisi:ments
followiag:
are tl.ie
a) Fiotel Alindahaw, pagadian City
b) Aiindahaw L,akeview Resort, Lakeview, zamboanga del s*r
^
v) Pensionne Yilana, Fagadian Cily
d) Boss Coffee, Pagadian City
e) ivfcDonald's, Pagadian City
0 Building Resources, pagad"ian City
oI
bt Jetti Gas Station, pagadian ")ity
h) I-and Transportation Office, :ragadian Cifv
i) cerilles (sKT) Labangan warehoue, Labangan, zanaboanga dei sur
i) Bb-gan;an Broaccasting cortr,oration Eruilding, pagadian
ci{y
ki She11 Gasol"ine Station, pagadian City
1) Vetera^rs Bank Btlilding, pagaciian Ciqy
m) Philippine Para-&{edicai arid Techni.cal school, Enericl co:iipaui:.c,
Pagadian City
Page 6 of 3.i
&ffidawit cf Fedro #. ffiai.nireu,.!n.
7. 21' Then Governor Aurora ceilles assigned Ruel
G. Moli*a anc tlrr,rne
singgo, who were her chiefs of staff, to overse" trr* withdrawal
and their delivery to the private estahlishments of the mareria-ts
of the cerilles coupie. The
couple also assigned Provincial Er.ldget officer,
Roger Monteaito, to oversee tire
preparation of the necessary d.ocurnents for
the payment of the delivered
materials' And I was instfi-lcted to issue the check for
the r:ayr.nent ol ti:*
covering ciisbu rseirrent vouchei-"
22' The "sl:pporting cocurnents", such as purchase request,
absir-a.*1; ci
canvass' BAC re;olution, purchase order, inspection
and acceptance i.epcrr,
etc', of the disbursement vouchers were all FALSIFitrD.
These were prepare*
by the suppiier upon the direction of Roger Montealto.
i{e is kno,wn as the
"Idagician" for being able to com.e up with the
source of funds, the pro;es:i io
whicir these rnaterials were charged, anc devise a .,ghost
construction rnateriais, off?ce materials and" equipment. ceiiveryl cf
The construction
materials welre often charged *.o the Amusement and
Events centei. {AEC),
located inside the Provincial capitoi cornplex, whi.ch
has been an o^t*g;ing
project for a long period of tirne;
23' As soon as the "suppoi:ting papers" were completed,
I
disbursernent rrouchers were theri prepaied and
the cciv*ring
the corresporlrling checks
/ issued' These checks were prioritized for payment- as emphaticaily
ordered 1:-v
the Ceilles cou.ple;
m$
. r.
ll
II 24' Thus, i hereby support and ,;onfirm the allegations of
iland xlrrone D' singgo in their Joint complaint-Affr<lavit
Ruel G. Mc.lina
whichr they signeri on
U Jarruary 11, 2Q12 iir the City of Man..la that
various constructiori materrais,
office supplies and equipment and ev:n bags of rice anc
grocery iren:s vere
u'ithcrawn frorrr r-he Golden Daughter Enterprises on different
accasions *nd
delivered to the private establishrnents and residence
of the ceriiles ccui:ie. i
have personal knowledge of these deliveries for the reason
that i signei rhe
disbursernent vor-1.c1-lers and the checks covering these delivered materials;
Fauored &sppliers an"d" Contractors
25' As repeatedtry instructed to rne by t.he Cerilles cor:ple, the
favoreu
suppiiers and contractors of the coupl.e were paid first. As
soon as the Internal
Revenue Allotment {IRA} was received, the cerilies couple
gave rne lists or iictes
indicating the suppiiers and contractors to be paid and the
respective ar-ncunts.
The foiiowing are the favored suppliers and conti-actors
of the Cerilies rvhich
have been granted most of the supply and consiruction projects
an4 p::;*rit;;re*
for payment:
a) Lr.rciqy Saver General Mercharrdise
b] Golden Daughter Enterprises
c) A..J. Enterr:rises
Page / of 13.
&ffidawit of Fed:"o D. Rannlrez, Jn.
8. d) E.L.B" Enterpises
e) Alajeno Construction
f) ZMS Construction
Attached, as Anrrex oo" to Annex *L)o, are copies
of some of the directives af ihe
ceriiles couple t{, -r.e, and mace an intr.gral part hereof;
26' wher: I issued checks without the afore-said prior directive,
then
Governor Aurora ceriltres asked me to exptrain and
show my basis for issuing
the checks, especially wLren these were i.ssued to orcinary
suppliers. ALtache.l,
as Annex "V', is a copy of a witten order for rne to
expiain which is maie an
integral part hereof;
unrernitted Brfi withhotding Toxes & Gsfs contribwtians
27 ' The Eross rnismanagement of the fund.s
resultec in the r.,on-
payment of rnanCatory obligations, non-rerni.ttance
of v/ithholcing io tiie
BIR and Pl"erniurns and. Salary. Loan antortizations to the Taxes ,*rhichl
GSIS,
consequently disqualified the provinciatr employees front
avaiiing of t1:e 1:e*ef;ts
fnorn the GSIS;
28' The comrlrission on Audit {CcA} has discovered r-ire faiiure
Provincial Governrnent to rernit to ttre aforementioned agencies
cf the
l regular annuatr audit. Thus, curi::g its
lt one of, the IinAlings in the COA Audit Reparr in tj^re
II years 2010" 2009 and 2008, include tire non-remittance of Withhoiding Taxes
to the BIR;
rl
2O 1O Audif Egpprt (During the terrns of the Ceriiles couple)
LS. E.Im.rexm,i*ted wi&hheld taxes +fl #SSrI"69r?B#.#6 iasesee.sed
fuy
$#.v*V@/a f'nom prexriowe yee!. of #S$r4Ar[rf*f.fe
f.xe s'iola'&$.sm
&o *xistf.mg BXR ruXes e,md regulati,ome"
2oo9 Audit Report (During the term of Governor Aurora cerilles)
s' E{uge aro.oex$.t of w"i&&.&etrd gexee &ota!}*ug wfl sss,4&q$?Bf.$*
remaixaed r.anrepe,r,Eted &s at year-errd, iru wiarletiom t*r
exi.stimg B$$Q. rqelee amd regaalatiCIrls e&$eslmiug gewerruxmenr.&
fil*nds t<r posei&Ee Loss am,d/CIr mis&se.
2Qo8 4udit Report {During the term of Go,,,ernor Aurora cerilies}
4. wi,tfu3aeEd. taxce {m t&e tcta} mxsaou.mt o$" p
xd,4#sos#?.x$$
rexms.$med, ae at Srear-emd, im viwlatiern to exi.s&terg
rarles, am*
regtalat{c,ses isn. the wi,*hfu*}d.i,xrg ms}d remittaru*e e,f .f,m-rses
amm,
exposing So.lsegffime*t {tsmds *o poesibSe loss *md,1tlr lminrase,
Fage i of 13.
AffidavEt of Fedro D" Rarmirez, Jr.
9. ' Ti:e year-end balances of Due to
29
Provincial Gcvernrnent faiied Gstrs clearly shorv that
empl0yees'
to ren:it to the G*IS the premiums the
Ioan amortizations. per ccA and
2AA7 ta 2a11, the amounts Audit Report for the past fiv* ye*rs,
Due to GSILT, are as foil0ws:
Year
Arnount
201 1
P 74,29a,991.?g
20 i0
tr 74,261,006.55
2009
P 90, 199,355.41
2008
P 75,946,966.53
2AA7
tr 78,53 7,919.43
Attached, as Annex ,.Ifr/, to
Annex ..yr, are copies of a fe-w
."0 Dernancl Letters sent hv the GSIS of tl:e l.{ot_ice cl
3:nH:, to then Governoi. Au-rr:r:r
30' As orderec b'y then Governor
GSIS' were not prioritized" Aurora cerilles, payments to
Even though I have the chect<s But ai:.,:r
prepared' these I/ere not i'eieased per t" these agencies
her order, her.ce, they became
coA Audit Report lbr the years sta,e. ,rhe
2a06 anc 200g include a
s{-aie c}iecks' A copy finding cf unreleasecl
of a- list of stale checks mcstly
to the BIR for the pcr:ir:ci
attached, as Anne N"z,,and
,{nnex *z-t,,and
ffi[i;#ffi]_:;l*'" rcarle an
3 i ' I am executing this Affidavit
ior the purpose of {rling the
crirninaL and adininistrative appr:r:p; iate
cases against Govemor Antonio
former Gorerrlor {urora tr' cerilles L{. ceriiles afld.
zamboanga del {now Representative, Znd Disti-ict oi
l*"1)' and all persons who in one way or another might have
':onspired' confabulated and
corrfecerated in the commission
:rimes and offenses; in support of ti:e foregcing
of our application in the witness
securiqr and Beneflt Prograil; Fi-otecticn,
to confirrn the allegation" .r
nu"r
in their J.int complaint-Afndavit which G. L4oLina and
*n-Jr rlti'f*t
'--*--J *'' oJ12 in the city of they signed on
Maniia; anc for aii other lega-l
purposes. intenrs ar:d
IN wlTllEss WHEREOF, I have
}:ereunto set my hand on ihis rrlr: -,r.:i, . .
fiano or} **+ r/ -- ii.r,]'il,r
January,2013 atthe cityof
hilanila, Fhilippin""]"1rry
>
z_@=..-=-
<---- rpg>je$ 1)" ffinmruufl, J;r*.
Affiant-Compiainant
Page $ ,:rf 3.1
Affldav[t of Fedra S" Ramire;,.fr.
10. ),--"','
-JAhJ g 2tri3 i
SUTSCRIEED AND SWORN
to before me
2073 at the c1Y:lnn""rl-,"ir.lrippi*"*.
orn.r, ,on this _ day of january,
exhibited to me his
i:Tffi",i'i, iffi '"';l t :[ # xil p e'lu-Ti::: 1L",, * c ,lri.,,,er,s
-;
3o
; "
n{i
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ATIY rr[i
noc. rrto. dJl
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AffiM
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I, ptrDF(O
D" RAMIRtrZ, JR., of legal
lr Poblacion, Kumalafang, i-rn
.
^Bjt Filipino and resident of
b'o^nga del Sur, and Pagadial
after having been duly swo.., t" City,
in accordance with iaw, do hereby respecii,-.r_.
sa]': O"po*" ..,.c
U
*4,
,h" r";X*lJ 3x',,.'$:,:tfiffitrpr*i"'lt and I have canrsed the prepar:alion
or
TI-{AT I have personal
and allegations contained knowtredge and tirat ail the information, sta.l.enients
herein are irue ancl correct to
personal knowlerige; the best cf rnri
h
?HAT I herel:y certify that i
'prcceecing invoiving the irr* not commencec any othe;^ aciion or.
issues i* 1i-r"'supreme c"rl.t,
"*rr.there"t ; -r,
Appeals, or different Divisions the court cf
rind that to the best of *y p"rronal_know1ed.ge, ";;;;;;d;r*runal oi- aseiicy
pending in the supreme br,rrt, no such action c
l-hereof, or any othei tribunaf
the court'-ol appeals or d;;I;:"xi.iTI;I
*u* or agency; and
TFIAT should I iearn
that simiiar
is pending b'efore the supremeacourt, a-ction or proceecing has been filec, c;.
the corr.t of Appeals or the clifferent
Affidavrr J;-;-H"J.'*u*,n*,,,,
11. j"-x-;'"'-'*""-
...
divisions thereof'.-or any
court within five (5) days other tribunal, court or agency, tr srrarl so norii..
frorn such knowledge. _ __.^*, t1:,;
,*,,,*l}, Hf::,f'fiY:,k*il:ffi;T::,1", *, hand on thi s i 7.,. n6;, .',f
L'1
,,:----sEryk0 B. $*eesrsqm:4* J$r"
Afiiant-Complair:t
?E.., ^arn ftY,-^*--
SUBSCRIBED AND SWORN *i,[N t $ 2il13
to before me
2013rat the cir{:lrvranila,
License No' itiiippirr-".-irnrit.on this _ to day of Ja.r-ru;rry,
-i""u"a exhibited rne his
'Io4-95-oqglaz
February Zl,2Ol2 and,t" by the i,and-Transportaticn Di:i,,,er,s
."pi._ on February 13, 2015. office oil
(
_ ) ->-
Doc. No. s {f ATTY L
Page No. fuf Nfi"['ntii' i]UEi-lC* l.rt'1L IrEC. 3t,?(r1t
,Book No. X f NOTAitlAl". tS1trl!1:;!10 2,]iA.tl5s r).
Rlr*L ,.lir. 7ll(r:S
Series of 2O13 FTl+ Nil, Of g3it"52 r /i t12 NlLA.'
tUp Nf:r. 86/.1^1 ?f,i It/2'::.iZ'illi ML,,A.
i Ffltt l]Jltr 1',:,,Itl5 ']"nW- Zi]13]
h,l CL H ( 0ri,,lEri- i,rLi{(. E i,l0_ t V " n0 0 g l65ft
page i3. of lt
Affidarrit *f Fedrc D. Rannirez,,!r.