1. I have read the Respondent's response and find it dishonest and objectionable.

2. Not only is the Respondent's witness statement filled with falsehoods, but also dis-
plays an utter lack of respect for employees who have contributed to the Company.

3. I am just an employee, and I was brought in by the then CEO of the Company, Mr
Lim Soon Ying. He was and I believe still remains, a Shareholder of the Respondent.

4.
I was offered a position in the Company as Head, Creative Lead and if the
Respondent is questioning the authenticity of my Letter of Employment, I am
truly shocked.

5. This was the offer of Employment which I had duly accepted.

6. It is an undeniable fact that I commenced work on 9th May 2022 in accordance

with my Contract, and similarly gave due notice of my resignation, in accor-
dance with the same. I have acted at all times in accordance with the terms of
my contract.

7.
I was in fact tasked to do work that was often outside my scope and for the various
Companies set up by Mr Ricky Tan Eng Kiat, Mr Peter Lau SY, and Mr Lim
Soon Ying.

8. I now submit at Annex 1, clear evidence that I was doing work not just for
Web3re Technologies Pte Ltd or Goya Technologies Pte Ltd but also for
Europa Capital Pte Ltd and Digital Philanthropy Limited without being
paid separately by each of these entities.

9. Surely if there is any inter-company billing for my time, the Respondent is not saying
that this is something that I as an employee would have to address myself too?
Surely, that proposition is untenable.

10. I was also often required in the course of my work, to pay for expenses on behalf of
the group of Companies, and then seek reimbursement from the Respondent.
How the Respondent allocated these costs and executed the fund transfers
between companies was never an issue raised during the course of my
employment.

11. I was also not obliged to make payment first on behalf of the Company but I did so as
a cooperative employee, as the Respondent did not have a corporate card until very
much later. An extract of some of these expenses is attached hereto at Annex
2.
Surely, it is not the suggestion of the Respondent that I was to make separate claims
for these expenses when I was facilitating the work of the Respondents?
 12. It was the Respondent’s duty, and more specifically Mr Ricky Tan Eng Kiat’s duty
to sort out the internal billing and fund transfers between the companies. I merely
expect to be paid for any advance payments made for and on behalf of the
Respondent or any of the companies within the Group.

13. I note with dismay and disappointment Mr Ricky Tan Eng Kiat’s allegation that I
have neither the relevant skills nor background to be Head, Creative Lead in
the Respondent. He does not however, explain why the Respondent has re-
tained my employment and paid my salaries and claims from inception to
the date of my resignation. Perhaps it is because he is not being truthful
before this Honourable Tribunal.

14. I enclose at Annex 3, clear evidence of Mr Ricky Tan Eng Kiat himself, liaising
with me in respect of both design work as well as work that I did on behalf of
the Respondent’s Mr Ricky Tan Eng Kiat for his other Companies.

15. Clearly, his instructions were for design work. In fact, all the Respondent’s company
logos, websites and marketing collaterals were designed by me and approved
by the Respondents as can be seen from extracts I enclose at Annex 4.

16. The Respondent seems to allege that it was Mr Lim’s idea to start the technology
business for the Respondent. From what I understand, the Respondents
started the business as an opportunity to earn interest income from a loan to Mr
Peter Lau’s friend and business associate, one Mr Simon Foo who was in-
terested in building an e-commerce and metaverse concert on the web and look-
ing for a loan. Instead of granting a large loan, the Respondent counter-of-
fered by offering to build the platform and take an interest instead, in the
business.

17. After the platform was completed, the Respondent’s Mr Peter Lau and the said
Mr Simon Foo fell out and the Respondents were left with a completed platform that
was then not utilised and unpaid for. The Respondents then pivoted to use the
platform built for other uses. I therefore verily believe that it is again, an
unsubstantiated and baseless allegation.

18. Throughout my tenure with the Company, I was involved in conceptualising and
leading the newly hired design and technical team to achieve the Respondent’s
design intent.

19. I enclose hereto at Annex 5 some excerpts of my correspondences with the

Respondents in respect of the approval of some of the designs conceptualised
by me.

20. I also note, that the Respondent’s Mr Ricky Tan Eng Kiat seems to allege that all
decisions, whether in respect of hiring or expenses are required to also be approved
 by him.

21. If this were so, it was certainly not communicated to the staff, nor to me. Indeed, the
Respondent’s memo as produced at Page [ ] and marked [ ] of the
Respondent’s submission clearly depicts the contrary.

22. As seen, it clearly states that all decisions or expenses are to be approved by either
Mr Lim Soon Ying OR Mr Tan Eng Kiat.

23. Who am I as just an employee to question the legitimacy or authority of the CEO of
the Company?

24. The Respondent has not come to Court with clean hands and is attempting to paint
a picture as a responsible Employer. This is however, further from the truth.

25. I have no wish to highlight the many disputes that the Respondent have and
continue to have with its’ other employees, but am forced to do so. I enclose at
Annex 6, copies of Letters of Demands sent by other Employees of the Respondent
who have not been paid their salaries to date which have been shared with me.

26. Clearly, it seems to be the Respondent’s behavioural trait to find excuses and trou-
ble with their ex-employees when they leave.

27. They have also told another ex part time employee, that the Respondent is “Broke”.
I enclose a screenshot of this at Annex 7.

38. I now turn to the Respondent’s allegation that I report to the CTO as claimed. I have
never been required to report to the CTO as alleged. Neither have i ever been hired
as an accounting/finance and admin staff with Web3Re or Goya.

39. My core duties involved design and coordinating design directions be it for the
metaverse, brochures, banners, etc as already elaborated and as evidenced in
the
Annexes.

40. I would also highlight that it was my designs that were used to trademark the logos
for GOYA, iCare and Family Wills.

41. I wish to emphasise that whatever internal shareholder disputes the Respondents
may have, or whether or not the Respondents wish to continue their business as a
ongoing concern has nothing to do with the Employees who have been hired and
should therefore be paid.

42. I respectfully wish to highlight to this Honourable Tribunal, that the very documents
produced by the Respondents show that acting on the instructions of my CEO
whether in respect of additional work or incurring expenses are valid and sufficient
to entitle me to be reimbursed and paid.
43. How the Respondents wish to “treat” or “account” for such inter-company related
expenses have nothing to do with me as I am merely an Employee following
instructions and pray that this Honourable Tribunal sees through the deception of
the Respondents and makes the necessary orders to compel them to release my long
overdue monies to me.