Republic of the Philippines)

Pasay City, Metro Manila ) s.s.

AFFIDAVIT OF MERIT IN SUPPORT OF APPLICATION FOR

ISSUANCE OF PRELIMINARY INJUNCTION

I , LIN XIAOQING , of legal age, Chinese citizen, single and with

residence at at No. 118 Kanlaon St., Ayala Alabang Village, Muntinlupa
City, having been duly sworn in accordance with law, hereby state that:

1. I am the authorized representative of the plaintiff corporation in a

complaint for temporary restraining order and preliminary injunction filed
before the Regional Trial Court of Pasay City, entitled “Big Emperor
Technology Corp. Represented by LIN XIAOQING vs. XIONWEI
TECHNOLOGY CO. LTD., INC.; PHILIPPINE AMUSEMENT AND
GAMING CORPORATION (PAGCOR), and docketed as Civil
Case No. _____________before the said court.

2. Said action involves a closure order dated 20 October 2022 signed and
issued solely by Assistant Vice President Atty. Victor Q. Padilla of Philippine
Amusement and Gaming Corp without authority from the board and without
observe of the fundamental requirements of due process. Ostensibly it was
supposedly issued on the advice of XIONWEI TECHNOLOGY CO. LTD.,
INC that they had canceled our contract with them.

3. The said closure order was personally served to us on 26 October 2022

and was sought to be immediately executed to the detriment of company’s
stakeholders including hundreds of workers who will be displaced
economically. We were in the dark as to the basis thereof since there was no
notice whatsoever sent to us by XIONWEI.
4. It was only on 28 October 2022 that we received the first notice from
XIONWEI, however, under our service agreement we still have a thirty (30)
day period to remedy the breach, hence, the contract remains valid and
binding.

5. In order to protect our rights as there is a valid and binding contract

between us and XIONWEI it is respectfully submitted that XIONWEI
TECHNOLOGY CO. LTD., INC and PAGCOR must be prohibited and
enjoined from committing further acts of enforcement of the closure order
through an ex-parte temporary restraining order and , after notice and
hearing, through a preliminary injunction.
6. The commission or continuance of the foregoing acts complained of during
the course of litigation, if not restrained by way of TRO/preliminary injunction,
would work injustice and irreparable harm upon our company BIG
EMPEROR TECHNOLOGY CORPORATION and its stakeholders.
7. Plaintiffs-applicants are entitled to the reliefs prayed for in their complaint,
and part of such relief consists in restraining the commission or continuation
of the acts complained of, the above-described acts being violative of
plaintiff’s rights under its contract with XIONWEI and its right to due process.
8. Unless exempted by this Honorable Court, plaintiff is willing to post a
reasonable amount of bond in support of its application for issuance of a writ
of preliminary injunction against XIONWEI and PAGCOR.

IN WITNESS WHEREOF, I hereto affix my signature this 3 rd day of

November 2022 in Pasay City, Philippines.

LIN XIAOQING
Affiant

SUBSCRIBED and SWORN to before me by affiant with who exhibited

his ______________________ID as competent evidence of identity.

WITNESS MY HAND AND SEAL this 3 rd day of November 2022 in

Pasay City, Metro Manila.

NOTARY PUBLIC