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November 29, 2019

ATTY. ROLANDO CASAWAY


Counsel for Delgar Holdings Corporation
Rizal Street, Tagum City
Davao del Norte

Dear Atty. Casaway,

We write on behalf of our client, Myell T. Abujos, with regard your client’s
obligation arising from the Joint Memorandum of Agreement executed on August
28, 2016.

It may be recalled that a Joint Memorandum of Agreement was executed


with regard the sale of the parcels of land covered by Transfer Certificates of
Title Nos. 142-2014002346 and C-16985. It is imperative to stress that paragraph
8 of the said agreement stipulates your client’s obligation to our client, to wit:

“8. That the said balance of P1,240,607.00 (less other expenses as


herein below stipulated) shall be paid by the BUYER to SELLERS-
A and SELLERS-B as represented by MyellAbujos and Abigail
Abujos, upon receipt by the BUYER of the titles of the subject
properties already registered in its name, or in the name/s of its
nominee/s or assign/s;”

Nota bene that it has been more than three years from the time that
all the documents for the processing of the titles were transferred in your
possession. Despite several follow-ups made by our client to hasten the
process, regrettably, it appears that nothing has been forthcoming to expedite the
same. As a result thereof, our client has been deprived of enjoyment and
utilization of the remaining balance as state in paragraph 8 of the Agreement.

It is our policy that before taking any drastic action, we give the obligor
concerned the last opportunity to settle this matter outside Court, to save it from
the unnecessary inconvenience and added expenses attendant to litigation.

In view of the foregoing, formal demand is thus made for you to expedite
the processing of the documents. Otherwise, our client will be left with no other
recourse but to file the appropriate civil, administrative and/or criminal case
against you without further notice.

It would be greatly appreciated if you could give this matter your


preferential attention.

Sincerely yours,

ATTY. SHERRYL JOY N. CASTILLO, CPA


Counsel for Myell C. Abujos

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