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WRITING ASSIGNMENT #2: COMPLAINT- AFFIDAVIT

Involved is a corporation called Hayahay Beach Resort Corporation (the “Corporation”), which
owns and operates the Hayahay Beach Resort in Doljo, Panglao, Bohol (the “Hayahay Resort”).
Copies of the Articles of Incorporation, By-Laws, and the 2008 General Information Sheet of the
Corporation on file with the Securities and Exchange Commission are on file. 40% of the shares is
owned and held by Patrick Swayze, British and resident of Panglao, Bohol, while the remaining
60% are held by four Filipinos, namely, Emma, Greta, Shayla and Wayne, all Filipinos and
residents of Panglao, Bohol.

Patrick met Emma sometime during the last quarter of 1999 in Alona Beach Resort in Panglao,
Bohol. She informed Patrick that she has a five thousand square meter (5,000 sqm.) beach-front
property in Doljo, Panglao, Bohol (hereafter referred to as the “beach-front property”). She enticed
Patrick to invest in the development of her beach-front property into a resort.

After seeing the property, and discovering its proximity to some of the best dive spots in the
Philippines, Patrick agreed to invest his hard-earned money and develop the beach-front property
into the world-class resort it is now, which is the Hayahay Resort.

It was agreed that Emma’s contribution to Hayahay Resort would be the use of the beach-front
property which she will lease to the corporation that they would eventually incorporate, i.e. the
Hayahay Beach Resort Corporation.

Pursuant to this agreement, Emma, with the assistance of her lawyers, executed a Contract of
Lease over the beach-front property with the Corporation on 22 September 2000 (the “Lease
Contract”). A copy of this Lease Contract is on file. Patrick paid for all the expenses for the
incorporation of the Corporation, including the subscriptions of Emma and the other Filipinos.
Patrick was informed, however, that since he is a foreigner, he cannot own more than forty percent
(40%) of the Corporation. Thus, while he paid for all the paid-in capital for all the shares
subscription of the Corporation, including Emma’s sixty percent (60%) interest, he was reflected as
the owner of only 40% of the Corporation. In addition to paying all the paid-in capital of the
Corporation, Patrick also paid for all the expenses for the construction of the Hayahay Resort into a
world-class resort.

Also, using his hard-earned money, he put up a dive center at the Hayahay Resort and bought all
the necessary equipment for diving and other water activities which may be leased by Hayahay’s
customers who were into diving and other water sports (the “dive center”).

It was agreed with Emma and the incorporators of the Corporation that since revenues and profits
from the dive center will belong solely to Patrick since Patrick purchased all the equipment and the
facilities of the dive center using personal funds.

From the time Hayahay Resort and dive center started operations around December 2000 up to
March 2018, the revenues in the dive center were regularly remitted to Patrick within the first week
of each month. However, Patrick became concerned when his revenues/profits from the dive
center for April 2018 were not remitted to him within the first week of the said month. The same
thing happened for revenues/profits from the dive center for the months May, June, and July,
of this year. Printouts of the monthly statements of revenues/profits earned by the dive center
from April 2018 up to the present were accessed and the above documents indicate that the dive
center earned net profits (net expenses and taxes which were deducted/ withheld by the
Corporation) which Emma and the other directors of the corporation kept in the sum of at least Php
6,000,000.

Patrick has engaged your services to prepare a complaint- affidavit for him and file the
same with the appropriate office.

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