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REPUBLIC OF THE PHILIPPINES NATIONAL CAPITAL JUDICIAL REGION REGIONAL TRIAL COURT BRANCH QUEZON CITY JOSE ESCAPO

and 2016 TCC suing as a representative of said corporation and stockholders, Plaintiffs, Civil Case No. __________ For: Derivative Suit Reconveyance of Property vs. HA, FJE, JL, FS, RC and the Corporate Secretary, Respondent. xxx-------------------------------------------------xxx COMPLAINT Plaintiff, by counsel, this Honorable Court respectfully alleges that: I PARTIES 1.0 Plaintiff, Filipino of legal age, married, with postal address at _______________ where he may be sued with orders, resolutions and decisions of the Honorable Court 1.1 Respondents FJE, JF, FS, RC are officers and directors of 2016 TCC with principal address at West Avenue, Q.C. where they may be served summons. II STATEMENT OF FACTS 2.0 Plaintiff share of 2016 TCC which 2/3 share of the outstanding Capital Stock, attached hereto, and is integral part of Certificate of Stock. 2.1 2016 TCC owns parcel of land with TCT 20648 located in Carmona, Cavite; 2.2 TCT _________ is the sole property of the Corporation; 2.3 May 12, 2012 the respondents allegedly met and approved Resolution No. 1 authorizing the president to negotiate with interested buyers to sell properties; 2.4 2016 TCC eventually sold the property to H. Alvarez for sum of Php60,233.131. and

III FIRST COURSE OF ACTION 3.0 Section 40 of Corporation Code require that SLEM 23 of SH. Contrary to requirements of Section 40 the plaintiff was not informed of the meeting held on May 12, 2012;

which case. e-mail address Allegations That in _______ case for expulsion of the President FJE was filed before the SEC as Estrada v.3.2 Since Resolution No. 42209 MCLE III Date Address Tel. 1 s. Date Location IBP No.2 In order to deter like intended individuals for committing the same illegal acts the respondents should be held liable for Php__________ as exemplary damages.3 Because the plaintiff was constrained to hire the service of counsel in order to protect his right and which the respondent should pay attorney fees. Tamong PTR No.1 TC ____ represent sole asset of the company 2/3 vote of SH is required for the meeting. Philippines. Alvarez. PRAYER WHEREFORE. .1 Because of ___________ the plaintiff suffered sleepless nights. No. 4. anxiety for which he is to recover moral damages in the amount of ______________. How to Subscribe: Subscribed and sworn to before me. a) reconveyance of TCT b) moral damages in the amount of ___________ c) exemplary damages in the amount of __________ d) attorney fees in the amount of _____________ Other reliefs and equitable in the premises are likewise prayed for at location respectfully submitted ___________ By: Vic Paolo K. Date Location Roll No. premises considered. 4. 2012 was firm all IV SECOND COURSE OF ACTION 4. Escudero SEC. 4. remains pending to dated ____________. a notary public for Quezon City this 7th day of June 2012 at ________. 3. NO. the plaintiff is entitled to the reconveyance of the property and the fruits obtained during the period of possession of Mr. plaintiff respectfully pray for the ff.0 Because of reckless illegal and malevolent action by the respondent officers.