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Republic of the Philippines)City 

of Davao ) S.S.x----------------------------------- x
 JOINT COMPLAINT-AFFIDAVIT
The undersigned
Complainants
, ANDY D. PATRICIO, CATHERINECAMAROTE, JS JOHNAREY B. ROSAPA, BENIDA
S. RAMOS, JOVYABAD and GIANCARLA RIVAS all of legal age, Filipinos, whose
addressesare stated hereunder, after having been sworn in accordance with law,hereby
depose and state that:1.
 
This criminal action is being filed to hold into account the FOUNDERS,OWNERS,
OPERATORS and PROPRIETORS as well as the namedCO-CONSPIRATORS of
CROWD ROYALS REAL ESTATESERVICES, an enterprise operating on the funds
solicited from thepublic, conspiring or confederating with and mutually helping
oneanother, and confederating as a syndicate, by means of false pretensesor fraudulent
acts executed prior to or simultaneously with thecommission of fraud to the effect that
Respondents have the business,property and power to solicit and accept investments
from the generalpublic, when in truth and in fact, they have no license or authorityfrom
the Securities and Exchange Commission (SEC) to do so, andcapacity to pay the
investors of CROWD ROYALS REAL ESTATESERVICES, including the undersigned
Complainants, the guaranteed50% to 200% monthly interest on said investments and
by means ofother deceits of similar import, induced and succeeded in inducing
theundersigned Complainants to invest, deposit, give and deliver to theRespondents
money as investments, Respondents knowing fully wellthat said pretenses and
representations are fraudulent scheme toenable them to obtain said amount, and
thereafter, having in theirpossession said amount, with intent to gain and to
defraud,misappropriated and converted the same to their own personalbenefits to the
damage and prejudice of the undersignedComplainants, in the aforementioned
amount.2.
 
When the following Respondents committed the foregoing actsattributed to them in this
Complaint, they did so while being the
FOUNDERS, OWNERS, CEO’s
of CROWD ROYALS REAL ESTATESERVICES and their other CO-CONSPIRATORS,
whose last knownaddresses are stated below their names, where they may be
servedwith the processes of this Honorable Office:
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i.
 
EDMON QUINONEZ
, Co-Owner, Co-Founder and Proprietor ofCROWD ROYALS REAL ESTATE
SERVICES, with last knownaddress at K. 18, Purok 13, Tibungco, Davao Cityii.
 
 JUDY ANN DELATINA-ESTRELLA
, Co-Owner, Co-Founder andProprietor of CROWD ROYALS REAL ESTATE
SERVICES, withlast known address at Camp Catitipan, Davao City.iii.
 
ARMANDO “MAX” OPPUS
, Co-Owner, Co-Founder andProprietor of CROWD ROYALS REAL ESTATE
SERVICES, withlast known address Lunar Street, Dona Vicenta Village, Bajada,Davao
City, Philippinesiv.
 
PO3 PETERNO EREDYL PALAMOS ESTRELLA
, COCONSPIRATOR, husband of JUDY ANN DELATINA-ESTRELLAwith last know
address at Camp Catitipan, Davao City.v.
 
TOMMY TOM CASAS,
CO CONSPIRATOR, with last knownaddress at La Verna Subdivision
NATURE OF THE CHARGES
3.
 
The undersigned Complainants charge Respondents with SyndicatedEstafa defined
and penalized under Article 315 (2) (a) of the RevisedPenal Code in relation to Section
1 of Presidential Decree No. 1680, asamended by Republic Act 10951 AND for violation
of Section 8 inrelation to Section 73 of the Securities and Regulation Code
(R.A.8799).4.
 
The violations arose out of the Respondents’
deliberate, willful andmalicious acts or omissions by means of false pretenses
and/orfraudulent schemes and machinations, to the effect that Respondentsmade it
deceptively appear that they have the business, property andpower to solicit and accept
investments from the general public, whenin truth and in fact, they have no license or
authority from theSecurities and Exchange Commission (SEC) to do so, and
likewisemade it fraudulently appear that they have the capacity to pay theinvestors of
CROWD ROYALS RELAT ESTATE SERVICES includingthe undersigned
Complainants, the guaranteed monthly interest onsaid investments and by means of
other deceits of similar import,induced and succeeded in inducing the undersigned
Complainants toinvest, deposit, give and deliver to the Respondents money
asinvestment, without payment of the same, to the damage andprejudice of the
undersigned Complainants.

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BRIEF STATEMENTS OF RELEVANT FACTS ANDCIRCUMSTANCES
1.
 
From April 9, 2019, to circa, July 26, 2019, herein RESPONDENTSEDMON
QUINONEZ, JUDY-ANNE DELATINA-ESTRELLA and
ARMANDO “MAX” OPPUS, as founders, owners and operators of
CROWD ROYALS REAL ESTATE SERVICES, as well as their CO-CONSPIRATORS,
the RESPONDENTS, PO3 PETERNO EREDYLPALAMOS ESTRELLA and TOMMY

TOM

 CASAS, has beencollecting, gathering and or otherwise taking money from the
public,including herein Complainants, through or by means of false
pretensesand misrepresentations.2.
 
The modus operandi of herein Respondents is briefly synthesized asfollows:First,
Respondents, EDMON QUINONEZ, JUDY-ANNE DELATINA-
ESTRELLA and ARMANDO “MAX” OPPUS, as founders, owners and
operators, would hold out to the public, including hereincomplainants, that Crowd
Royals Real Estate Services is a UnitedStates based Company dealing in the buying
and selling of securities,such as the Foreign Exchange and Gold, with international
basedtraders.Thereafter, herein Respondents would inform herein complainantsand the
investing public,
that if the latter, would give or “invest” their
money in Crowd Royals Real Estate Services (hereinafter referred to as
“pay
-
ins”)
, the complainants would receive a guaranteed interest of50% to 200% after the lapse
of 30 to 45 days (hereinafter referred to as
“payouts”)
. An alternative fraudulent scheme by which therespondents would entice the investing
public is that upon thepayment of the latter of 25% of the value of a particular real
property,after the lapse of 30-45 days, the property would now belong to theone who
paid the said 25% value thereof.Another modus operandi, presumably in order for the
respondents toattract more of the investing public in different parts of the Philippinesor
particularly Mindanao, is that the Respondents, through the samefalse and fraudulent
misrepresentations previously stated, offeredseveral proposals to herein complainants.
The proposal was to theeffect that a small commission would be paid to the
complainants, ifthe latter would agree that payment to Crowd Royals Real Estate

 
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Services would be coursed through them or received by them, atdifferent points in
Mindanao, which includes but is not limited to,Digos City, Kapalong, Banay-Banay and
Malita and thereafter remit ordeliver said payments to Crowd Royals Real Estate
Services withrespondents EDMON QUINONEZ, JUDY-ANNE DELATINA-
ESTRELLA and ARMANDO “MAX” OPPUS, as founders, owners and
operators thereof.Relying in Good Faith on the incessant false assurances and
fraudulentmachinations of herein respondents, the complainants agreed on theafore-
cited proposal of respondents EDMON QUINONEZ, JUDY-ANNE DELATINA-
ESTRELLA and ARMANDO “MAX” OPPUS, as
founders, owners and operators of Crowd Royals Real Estate Services.Herein
Respondents, EDMON QUINONEZ, JUDY-ANNEDELATINA-
ESTRELLA and ARMANDO “MAX” OPPUS, as
founders, owners and operators of Crow Royals Real Estate Serviceswould constantly
and repetitively assure, guarantee and promise thecomplainants that they had the
necessary authority to conduct thiskind of business and that Crowd Royals Real Estate
Services wasindeed a legitimate enterprise.To perpetrate further the fraud committed by
the respondents to thedamage and prejudice of herein Complainants, the
guaranteedinterests, as well as the capital invested of the investing public waspaid
and/or otherwise delivered by the respondents, in the early partof the scam. Thereby
adding a sense of false legitimacy to the businessin furtherance of the fraudulent
scheme of herein respondents.It should also be noted that all the pay-ins received are
delivered andtransmitted to either Edmon Quinonez, Judy Anne Delatina-Estrella
and Armando “Max” Oppus
 at the end of every working day. This isevidenced by the
logbook
, which has entries of the amounts receivedby the latter persons and the date of receipt
with their correspondingsignature.
Copies of the entries of the Logbook are hereto attached as Annex “A”,
with sub-markings, and made an integral part of this Joint-AffidavitComplaint.However,
not all transactions were recorded in this Logbook, as thereare times when
the respondents would take the money personally andwould not report it to the Crowd
Real Estate office and its employees.

 
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The fraudulent machinations of the respondents came full circle whenthe respondents,
sometime on July 26, 2019, disappeared, taking withthem several hundreds of millions
of pesos, which are supposed to bepaid to the investors, which includes herein
complainants.The participation of respondents, PO3 PETERNO EREDYL
PALAMOSESTRELLA and TOMMY TOM CASAS as co

 conspirators, involvedthe taking of the cash from the investors and delivering them
to any ofthe three founders, operators and owners of Crowd Royal Real EstateServices,
despite not being the cashiers of Crowd Royals Real EstateServices. PO3 PETERNO
EREDYL PALAMOS ESTRELLA andTOMMY TOM CASAS are not even employees of
Crowd Royal RealEstate Services and are not part of the payroll. PO3
PETERNOEREDYL PALAMOS ESTRELLA and TOMMY TOM CASAS wouldalso
accompany EDMON QUINONEZ, JUDY-ANNE DELATINA-ESTRELLA or
ARMANDO “MAX” OPPUS
, as the case may be, insome meetings with investors and would almost always be
seentogether with them. PO3 PETERNO EREDYL PALAMOS ESTRELLAand TOMMY
TOM CASAS disappeared together with EDMONQUINONEZ, JUDY-ANNE DELATINA-
ESTRELLA and ARMANDO
“MAX” OPPUS
.3.
 
The above-described fraudulent modus operandi of the respondentsbegan as early as
April 9, 2019. As this is the earliest record of Pay-insby the investing public to EDMON
QUINONEZ, JUDY-ANNEDELATINA-ESTRELLA
and ARMANDO “MAX” OPPUS
 as ownersand operators of Crowd Royals Real Estate Services.As evidence of
the foregoing, Several Membership Forms dated April9, 2019, stating the names of the
investors, their addresses, who aremostly from Davao City, the amount paid by the said
investor andbearing the name and Logo of Crowd Royals Real Estate Services, is
hereby attached as Annex “
B
” and made an integral part of this Joint
Affidavit Complaint.4.
 
On April 22, 2019, the Office of Crowd Royal Real Estate Services,located at Salvacion
Panabo, Davao del Norte, with , EdmonQuinonez, Judy Anne Delatina-
Estrella and Armando “Max” Oppus
as founders, owners and proprietors thereof, opened and had its soft-launching.

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5.
 
The previous day, On April 21, 2019, Edmon Quinonez, Judy AnneDelatina-
Estrella and Armando “Max” Oppus as founders, owners
and proprietors hired as employees the following persons:a.
 
Leah Aming, as Admin Officer of the office in Panabo Davao DelNorte.b.
 
Mildred Ocon, 22 years old, as front desk staff of theaforementioned office in Panabo,
Davao del Norte.c.
 
Maria Princess Margartia Cagas, 20 years old, as front desk staff ofthe aforementioned
office in Panabo, Davao del Norte.d.
 
Mariam Gesalam, 36 years old, as an cashier/accounting staff ofCrowd Royals Real
Estate Services, stationed in the said office inPanabo, Davao del Norte.e.
 
Aziza Manzawe, 20 years old, as an encoder of Crowd Royals RealEstate Services,
stationed in the said office in Panabo, Davao delNorte.f.
 
 Janice Barjana, as an accounting staff of Crowd Royals Real EstateServices, stationed
in the said office in Panabo, Davao del Norte.6.
 
The office of Crowd Royal Real Estate Services at Salvacion, Panabo,Davao del Norte,
was officially launched on April 28, 2019.7.
 
On May 9, 2019, the Crowd Royals Real Estate Services under thedirection and control
of Edmon Quinonez, Judy Anne Delatina-
Estrella and Armando “Max” Oppus as founders, owners, operators
and proprietors thereof, released money to the first investors,including the guarantee
d 50% interest (hereinafter referred to as “pay
-
out”).
 8.
 
Sometime in the second week of June, 2019, under the expressinstruction and
command of Edmon Quinonez, the office of CrowdRoyals Real Estate Services was
transferred to a place where Tuna wasbeing
processed (hereinafter referred to as “pangahan”), located at
Tibungco, Davao City, which is owned and operated by EdmonQuinonez.9.
 
Likewise, under the express instructions of Edmon Quinonez, JudyAnne Delatina-
Estrella and Armando “Max” Oppus as founders,
owners, operators and proprietors of Crowd Royals Real EstateServices, the encoding,
pay-ins and pay outs were also being

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conducted at a condominium unit in Palmetto Place, in Maa road
Davao City. This was a Condominium unit owned by Armando “Max”
Oppus.10.
 
On circa, the second week of July, 2019, likewise, under the expressinstructions of
Edmon Quinonez, Judy Anne Delatina-Estrella andArmand
o “Max” Oppus as founders, owners, operators and
proprietors of Crowd Royals Real Estate Services, the encoding, pay-ins and pay outs
were also being conducted at a house/building inDeca Homes, Davao City.11.
 
Indeed, after the office in Salvacion, Panabo, Davao del Norte wasclosed down by
express instructions of Edmon Quinonez, Judy AnneDelatina-
Estrella and Armando “Max” Oppus, the pay
-ins andpayouts were being conducted anywhere. Sometimes, EdmonQuinonez, Judy
Anne Delatina-
Estrella and Armando “Max” O
ppusas founders, owners, operators and proprietors of Crowd Royals RealEstate
Services would order and command the employees to getmoney from certain
individuals as pay ins, and deliver the same tothem.12.
 
The pay-ins and payouts of investments in Crowd Royal Real EstateServices seemingly
went smoothly and without any problems until July 26, 2019.13.
 
On July 26, 2019, herein respondents disappeared and had takenseveral hundred
million pesos, which were supposed to be paid to thecomplainants, as well as the other
investors of Crowd Royals.Accordingly, the respondents could no longer be contacted
throughthe mobile phones and online messaging applications which theywould normally
be contacted.14.
 
To date, the respondents are not yet found, and accordingly nopayment has been made
to the investors of Crowd Royals, includingthe complainants herein.15.
 
As a consequence of herein respondents acts of FraudulentMisrepresentations and
thereafter, absconding, and unlawfully takingwith them the money supposed to be paid
to the complainants and theother investors, amounting to several hundred million pesos,
hereincomplainants suffered damage and prejudice. In addition, hereincomplainants,
are also suffering damage and prejudice by the fact thatthey are constantly being
hounded and harassed by other investors ofCrowd Royals Real Estate Services for the
payments which wascoursed through them but was actually and wholly remitted by the

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To date, the named respondents with the money amounting to severalhundred million
pesos are still not located. The money the respondentstook was supposed to be paid to
the investors.

 
B.
 
STATEMENT OF FACTS AND CIRCUMSTANCES ON THEBASIS OF THE
PERSONAL KNOWLEDGE OF WITNESSES,MARIAM GESALAN, AZIZA S.
MANZAWE, JANICE BARTIANA,MILDRED OCON AS PROVIDED IN THE
ATTACHED SWORN JOINT AFFIDAVIT OF THE AFORE-CITED PERSONS.
3.
 
The Sworn Joint-Affidavit of Mariam Gesalan, Aziza S. Manzawe,
 Janice Bartiana, Mildred Ocon is attached hereto as Annex “
D
“ and
made an integral part of this Joint Affidavit

 Complaint.4.
 
For immediate reference and guidance of this Honorable Office, thestatements made in
the Sworn Joint-Affidavit of Mariam Gesalan,Aziza S. Manzawe, Janice Bartiana,
Mildred Ocon is herebyreproduced, to wit:We are employed at Crowd Royals Real
Estate Services. We are merelyemployees and as such is simply receiving a fixed wage
from CrowdRoyals Real Estate Services for our employment. We are not involvedin the
decision-making process concerning the affairs of Crowd RoyalsReal Estate Services.
Our duties are purely the duties of an employedencoder, accounting officer or Front
Desk Officer, as the case may be.On April 21, 2019, in preparation of the soft opening
of the CrowdRoyals Estate Services office at Salvacion, Panabo City, EdmonQuinonez,
Judy Anne Delatina-
Estrella and Armando “Max” Oppus
as founders, owners and proprietors of Crowd Royals Real EstateServices, hired us as
employees:a.
 
Mildred Ocon, 22 years old, as front desk officer of the aforementionedoffice in Panabo,
Davao del Norte.b.
 
Maria Princess Margartia Cagas, 20 years old, as front desk officer ofthe
aforementioned office in Panabo, Davao del Norte.c.
 
Mariam Gesalam, 36 years old, as an encoder of Crowd Royals RealEstate Services,
stationed in the said office in Panabo, Davao del Norte.d.
 
Aziza Manzawe, 20 years old, as an encoder of Crowd Royals RealEstate Services,
stationed in the said office in Panabo, Davao del Norte.

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e.
 
 Janice Barjana, as an accounting officer of Crowd Royals Real EstateServices,
stationed in the said office in Panabo, Davao del Norte.All the payments given by
investors or

pay-ins

 that we received asemployees of Crowd Royals Real Estate Services are
immediatelydelivered and remitted to either by Edmon Quinonez, Judy AnneDelatina

 Estrella and/or Armando Oppus, as founders, owners andproprietors of Crowd Royals
Real Estate Services, at the end of everyworking day.The said pay-ins that we remitted
are recorded in a logbook, with theamount and specific date, which were duly signed by
either EdmonQuinonez, Judy Anne Delatina

 Estrella and/or Armando Oppus,depending on who among the three received the same
on that day.However, there is a large number of pay-ins which were given directly
toEdmon Quinonez, Judy Anne Delatina

 Estrella and/or ArmandoOppus and not to us. As such, there is no record of the same
in thelogbook.Corollary thereto, the amount of money that Crowd Royal Real
EstateServices would give back to the investors as the
“pay
-
outs” would also
be given to us by Edmon Quinonez, Judy Anne Delatina

 Estrella and/orArmando Oppus. At the end of every working day, we would make
arequest for the amount of money from Edmon Quinonez, Judy AnneDelatina

 Estrella and/or Armando Oppus, to be paid to the investors as
“pay
-
outs”
 for the next day, the latter would then review, approve, lessenor deny it. Thereafter,
Edmon Quinonez, Judy Anne Delatina

 Estrellaand/or Armando Oppus
, would give us the amount to be paid as “pay
-
outs” to
 the investors, in turn at the end of every working day, anyunclaimed amount would be
given again to Edmon Quinonez, Judy AnneDelatina

 Estrella and/or Armando Oppus.As employees of Crowd Royals Real Estate Services,
we would observethat PO3 Peterno Eredyl Palamos Estrella, husband of Judy
AnneDelatina

 Estrella, would always accompany the latter in dealingsinvolving Crowd Royal Real
Estate Services business. PO3 Peterno EredylPalamos Estrella would be involved in
some meetings with investors andwould also personally receive money from investors,
despite not beingan employee of Crowd Royals Real Estate Services and not
receivingwages from the payroll.In the same manner, we would observe,
Tommy “Tom” Casas, always
accompany Edmon Quinonez Judy Anne Delatina

 Estrella and/or

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Armando Oppus, but most of the time, he would be with EdmonQuinonez. He would
also be present at some meetings of investors andwould receive money from investors,
despite not being an employee ofCrowd Royals Real Estate Services and not being
included in its payroll.
f.
 
STATEMENT OF FACTS AND CIRCUMSTANCES ON THEBASIS OF THE
PERSONAL KNOWLEDGE OF COMPLAINANT JS JOHNAREY ROSAPA
5.
 
On April 21, 2019, I delivered purified water to the Office of CrowdRoyals Real Estate
Services, being set up in Salvacion, Panabo, Davaodel Norte, being the owner of a
purified water station business.6.
 
While there, I met Edmon Quinonez, who talked to me and stronglyencouraged me to
invest in Crowd Royals Real Estate Services.Edmon Quinonez narrated and told me
that Crowd Royals Real EstateServices was a United States based Company, that it
traded in ForeignExchange and Commodities and had several traders from across
theworld. Likewise, I was told that the amount of money I invested inCrowd Royals Real
Estate Services, would be traded in ForeignExchange and the like and would have a
guaranteed interest of aboutfifty (50%), after about 30-45 days. Upon inquiry, He also
told me thatCrowd Royals Real Estate Services had the necessary permits toconduct its
business.7.
 
Having been persuaded and enticed by the words of EdmonQuinonez, I returned to the
office in Panabo, during their softlaunching the next day, April 22, 2019, and invested
a total amount ofone hundred seventy thousand pesos (P170,000.00).8.
 
In the following weeks, I was again persuaded and enticed by EdmonQuinonez, Judy
Anne Delatina

 Estrella and Armando Oppus, asfounders, owners and proprietors of Crowd Royals
Real EstateServices by another offer.The offer was, if a potential investor would decide
to invest theirmoney in Crowd Royals Real Estate Services, and the payment wouldbe
coursed through me and I would subsequently remit the same toEdmon Quinonez, Judy
Anne Delatina

 Estrella and ArmandoOppus, as founders, owners and proprietors of Crowd Royals
RealEstate Services., I would receive a small percentage as commission.

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9.
 
Believing in good faith that Crowd Royals Real Estate Services was alegitimate
business, I agreed to the offer, taking into consideration
therepeated assurances of Edmon Quinonez, Judy Anne Delatina

 Estrella and Armando Oppus, that indeed Crowd Royals Real EstateServices was a
legitimate business, and the fact that I had noknowledge, at that time, of any advisory
from any Government agencyto beware or warning me of investing in Crowd Royal Real
EstateServices, in particular.Also, the fact that there were already several payouts to a
considerablenumber of investors, added to my good faith belief that Crowd RoyalsReal
Estate Services was indeed legitimate.10.
 
Taking into consideration the foregoing, I talked to some of my friends,family,
colleagues and other people, about Crowd Royal Real EstateServices. I narrated to
them what I was merely told by EdmonQuinonez, Judy Anne Delatina

 Estrella and Armando Oppus aboutCrowd Royal Real Estate Services. Some of them
decided to investtheir money to Crowd Royal Real Estate Services and coursed
theirpayment through me, since a number of them had residences outsideof Panabo
City, where the office of Crowd Royal Real Estate Serviceswas located. I then, remitted
and/or otherwise remitted the paymentto Edmon Quinonez, Judy Anne Delatina

 Estrella and ArmandoOppus, as founders, owners and proprietors of Crowd Royals
RealEstate Services.11.
 
Sometime in the second week of June, 2019, under the expressinstruction and
command of Edmon Quinonez, the office of CrowdRoyals Real Estate Services was
transferred to a place where Tuna was
being processed (hereinafter referred to as “pang
a
han”), located at
Tibungco, Davao City, which is owned and operated by EdmonQuinonez.12.
 
From the time I invested in Crowd Royals Real Estate Services on April22, 2019. The
pay-ins and payouts of investments in Crowd Royal RealEstate Services went smoothly
without any problems until on July 26,2019, I received several text messages and also
in group chats inmessenger (Facebook) that Edmon Quinonez, Judy Anne Delatina

 Estrella and Armando Oppus, as founders, owners and proprietors ofCrowd Royals
Real Estate Services could no longer be located, cannotbe contacted through their
cellphones and that they took moneyamounting to several hundred million pesos, that
was supposed to beused as pay out on July 27 onward.

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