Affidavit (Mr. Martin)

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Republic of the Philippines)

City of Paranaque) S.S.


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AFFIDAVIT

I, MARTIN BONIFACIO, of legal age, single, with address


__________________, after having been duly sworn in accordance with law,
hereby depose and say that:

1. I work as Defendant’s consultant in her business hence I have


personal knowledge of the circumstances and events concerning the
transaction of the Plaintiff and Defendant. I am one of the supposed
witness for the Defendant in the case captioned as “Carolina D. Tan versus
Catherine Gawat Domelow” docketed as Civil Case No.R-MKT-18-04586;

2. I was with the defendant during the time that Plaintiff made
partial delivery of the workbook manuals for Kids and Kids Standards. Only
the workbooks manuals for Kids and Kids Standard were delivered. There
was no USB and Powerpoint presentation materials as identified in the
contract. The manual for Kids and Kids Standard are only 2 out of the 12
deliverables by the Plaintiff under the Contract.

3. During the day of PARTIAL delivery of the workbook manuals


for Kids and Kids Standard, Plaintiff did not mention if and when full
delivery will be made. There was also no statement/s or information as to
when the other modules will be delivered.

4. On 17 July 2019, by instructions of defendant, I caused the


delivery of the email to the Plaintiff Carolina D. Tan regarding the
cancellation of the Contract of Service. (copy of the email is attached as
Annex “4”).

5. At the time the notice of cancellation of contract was sent to


the Plaintiff, there was no information that the manuals were completed.

6. Plaintiff informed the defendant that the manuals were


completed only after the contract was cancelled. However, I have not seen
any copies of the manuals/workbooks.

7. I am executing this Affidavit to attest to the fact that the


Defendant has a meritorious defense against the Plaintiff if only be given by
the Honorable Court the chance to present her defenses.

IN WITNESS WHEREOF, I have hereunto set my hand this


_____________ at _________________, Philippines.

MARTIN BONIFACIO
Affiant

SUBSCRIBED AND SWORN TO before me this ____ day of


_____________ at the City of Paranaque, affiant exhibiting to me his ID card
no. ________________.

Doc. No. _______


Page No. _______
Book No. _______
Series of 2019

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