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REPUBLIC OF THE PHILIPPINES )

PASIG CITY ) S.S.

AFFIDAVIT

I, ____________________, Filipino citizen, of legal age, with address at


___________________________________, after having sworn in accordance with law, hereby
depose and state that:

1. I am the ___________________________ (or the “Company”), an Authorized


Agent Corporation of Small-Town Lottery of the Philippine Charity
Sweepstakes Office (“PCSO”) since _______________ until present in the
Province of Quezon. As proof thereof, a copy of the Certification issued by the
PCSO Vice-Chairperson dated ________________ is attached hereto as
“Annex A”;

2. Due to the COVID-19 Pandemic restrictions imposed across the country and
the changing of Quarantine Classifications, the Company had to stop its
operations in the Province of Quezon from March 2020 to September 2020 as
the National Government prohibited Small Town Lotteries to operate when a
locality is under a specific Quarantine Classification.

3. As a result, when Small Town Lottery operations in the Province of Quezon


resumed on October 2020, the Company was not able to anticipate and
prepare for the sudden increase in the number of bets which resulted to the
piling up of coins in our offices in the Province. The Company requested for
bank pickups but due to the volume of coins, banks in the Province refused to
accommodate our requests.

4. Beginning__________________, the Company has been reaching out to


PCSO regarding the Company’s concerns on the deposit of coins collected
from the operations.

5. Particularly, on December 09, 2020, since the volume of coins in the


Company’s possession has been continuously increasing, the Company sought
the guidance of PCSO through a letter of even date, addressed to Office of the
General Manager. In the said letter, the Company raised the abovementioned
issue which was primarily due to the restrictions imposed by banks on the
volume of coins to be deposited on a daily basis. A copy of the Letter dated
December 9, 2020 is attached hereto as Annex “B”.

6. On January 11, 2021, as we have not received a response from the PCSO, the
Company sent another letter to the General Manager of the PCSO reiterating
our request for guidance and for written guidelines on how the Company can
strategically move the coins for proper safekeeping while addressing bank
deposit issues. A copy of the Letter dated January 11, 2021 is attached hereto
as Annex “C”.

7. On January 15, 2021, the PCSO responded to our letters suggesting for the
Corporation to look for a secured area where the coins can be stored. Based
on the Letter, it appears that the PCSO has no secured space for storage of
coins and that its branches are also subject to the restrictions by the bank on
the allowable volume of coins to be deposited. A copy of the Letter from the
PCSO dated January 15, 2021 is attached hereto as Annex “D”.

8. As instructed by the PCSO in its letter dated January 15, 2021, on March 10,
2021, we sent a letter complying with the instruction of the PCSO to inform
them of the location of the coins. In the said letter, we informed PCSO that the
coins are being stored at 51 Scout Tuason Barangay Laging Handa Quezon
City as the Company continues to deposit the same while complying with bank
restrictions. The Corporation explained that the option to move the coins from
Quezon Province to Metro Manila was primarily due to the fact that only Metro
Manila branches have the capacity to accept such volume of coins. A copy of
the Letter dated March 10, 2021 is attached hereto as Annex “E”.
9. On March 16, 2021, through a letter of even date, the PCSO acknowledged the
receipt of our Letter dated March 10, 2021 regarding the location of the coins.
The PCSO instructed us to observe the proper security measures in our
storage area while they also exert coordination with the proper monetary
authorities on how to address the growing number of coins in our possession.
A copy of the Letter from the PCSO dated March 16, 2021 is attached hereto
as Annex “F”.

10. The Corporation continued depositing the coins in batches i.e., within the daily
limit prescribed by banks on deposits of coins. However, the volume of coins
we receive daily from our operations continued to increase and the number of
coins coming in were significantly higher than what we can deposit daily.

11. To our surprise, on October 01, 2021, the Bureau of Customs (“BOC”) and the
National Bureau of Investigation (“NBI”) raided the place where we safe keep
the coins and checked its authenticity. Results came out and it was established
that there were no counterfeits on the samples they took. As of the execution of
this Affidavit, the coins are being held under full control and sole custody of the
BOC.

12. On October 6, 2021, our office sent a letter to the PCSO informing the of the
raid conducted by the BOC and the NBI. We requested a certification from the
PCSO stating that our Corporation is a duly registered and accredited agent for
Small-Town Lottery (“STL”) operations. A copy of our October 6, 2021 letter to
the PCSO is attached hereto as Annex “G”.

13. On October 11, 2021, we wrote PCSO another letter seeking assistance to
request the BOC and NBI to release the Corporation’s properties, particularly
the coins used by the Corporation for its STL operations. A copy of our October
11, 2021 letter to the PCSO is attached hereto as Annex “H”.

14. On October 12, 2021, we were furnished a copy of the letter from the PCSO
addressed to the Director of the NBI stating that our Corporation is a duly
accredited agent for STL operations in the Province of Quezon and that the
coins seized during the raid were the result of the Company’s operations. The
letter states:

“Pirouette is the Small Town Lottery-Authorized Agent Corporation in the


Province of Quezon and is authorized to collect payment for the Small Town
Lottery games and pay prizes. The payment made by their bettors consist of
both of paper bills and coins which they consolidate and manage to pay prizes
of winners, pay the salaries of their employees and comply with its obligation
with PCSO.” A copy of the October 12, 2021 letter is attached hereto as Annex
“I”.

13. I am executing this Affidavit in my capacity as the President of Pirouette


Corporation, to attest to the legality of the volume of coins in the Company’s
possession, and to confirm under oath that the volume of coins resulted from
the Corporation’s legitimate and legal operations as a Small-Town Lottery-
Authorized Agent Corporation in the Province of Quezon. I am likewise
attaching relevant documents proving the legality of the operations of our
Corporation as follows: (a) Certificate of Incorporation attached hereto as
Annex “J”; (b) Authority to Operate attached hereto as Annex “K”; (c) Award
granted to our Corporation as Outstanding Authorized Agent Corporation by
the PCSO as Annex “L”.

14. I am executing this Affidavit to attest to the truth of the foregoing facts and for
the other legal purpose(s) this may serve best.

IN WITNESS WHEREOF, I have hereunto set my hand this ____________________ at


Quezon City, Philippines.

_________________________
Affiant

SUBSCRIBE AND SWORN TO before me this ____ day of October 2021 at Quezon
City, affiant exhibiting to me her identification document ____________________________.

Doc. No. _____;


Page No. _____;
Book No. _____;
Series of 2021.

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