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SPECIAL POWER OF ATTORNEY

I, DAVID AMAR DE JUAN, Spanish, of legal age, Manager of KONAIR US,


LLC (“Konair”) with office address at Puerto De Santa Maria 75B, Madrid, 28043,
Spain, do hereby appoint and designate DivinaLaw Offices (the “Firm”),
specifically, NILO T. DIVINA, ALDEN FRANCIS C. GONZALES, FLORO C.
BALATO JR., IAN JERNY E. DE LEON, ISMAEL L. SARANGAYA JR., or any other
lawyer or staff as may be appointed by the Managing Partner of the
aforementioned Firm, as my/Konair’s true and lawful representatives and
attorneys-in-fact, to take all the necessary actions on behalf of Konair, for the
purpose of handling the case of one (1) ATR42-300 aircraft bearing manufacturer’s
Serial 1, Number 128 and United States Registration Number N228DG, equipped
with two(2) PW121 engine’s bearing manufacturer’s Serial Numbers 120763 and
AC0014 (the “MSN 128 Aircraft”), including but not limited to the following:

1. Prepare, submit, and file all legal actions and remedies pursuant to
the case involving the above mentioned aircraft MSN 128 Aircraft with the Court of
Tax Appeals (“CTA”), any other courts of law, appropriate tribunals or
administrative or regulatory bodies here in the Philippines;

2. Prepare, submit, and file all necessary letters, requests, documents,


and cause and/or do any lawful act to secure the release and transfer possession of
the aforementioned aircraft to Konairour company from any Philippine
administrative or regulatory body, department, agency or bureau; legal actions and
remedies with the appropriate tribunals and/ or administrative agencies that may
be necessitated subsequent to the decision rendered by the CTA;

3. Sign the Verification and Certificate Against Forum Shopping


whenever necessitated by the legal action to be undertaken;

4. Execute, sign, submit, and file any and all papers, correspondences,
and documents as may be necessary in connection with any of transactions related
to the aforementioned purpose, of whatever nature;

5. Sign the appropriate Verification and Certificate Against Forum


Shopping whenever necessitated by the legal action to be undertaken;

6. To represent me/Konair in all proceedings, conferences and/or all


hearings in any case that may be filed relative to any of the foregoing matters and,
in connection therewith, agree on the following, if necessary:and

(a) The possibility of an amicable settlement or of a submission to


alternative modes of dispute resolution;

(b) The simplification of the issues;

(c) The necessity or desirability of amendments to the pleadings;

(d) The possibility of obtaining stipulations or admissions of facts and of


documents to avoid unnecessary proof;

(e) The limitation of the number of witnesses;

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(f) The advisability of a preliminary reference of issues to a
commissioner;

(g) The propriety of rendering judgment on the pleadings, or summary


judgment, or of dismissing the action should a valid ground therefor be found to
exist;

(h) The advisability or necessity of suspending the proceedings; and

(i) Such other matters as may aid in the prompt disposition of the
action; and

7. Do any and all acts, execute, sign, and deliver any and all
instruments as may be necessary and/ or required for the implementation of the
foregoing, with any and all third persons, concerns and entities, upon such terms
and conditions acceptable to said attorneys-in-fact.

HEREBY GIVING AND GRANTING unto my/Konair’s said attorneys-in-


fact full power and authority to do and perform any and every act, thing,
whatsoever requisite, necessary or proper to be done in and about the premises as
full to all intents and purposes as I might or could do if personally present and
acting in person, with full power of revocation and substitution.

AND HEREBY RATIFYING AND CONFIRMING all that said attorneys-in-


fact shall lawfully do and cause to be done under by virtue of these presents.

IN WITNESS WHEREOF, I have hereunto set my hand in this ___day of


_____________, 2019, in ________________________Madrid City, Spain.

………………………………………………
DAVID AMAR DE JUAN
Affiant

ACKNOWLEDGEMENT

REPUBLIC OF THE PHILIPPINES)


____________ ________________)S.S.

BEFORE ME, a Notary Public for and in the


_________________________City of Madrid, Spain personally appeared:

NAME VALID PROOF OF DATE AND PLACE ISSUED


ID.

DAVID AMAR DE JUAN

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known to me to be the same person who executed the foregoing Special Power of
Attorney, and he acknowledged to me that the same is his free act and deed.

IN WITNESS WHEREOF, I have hereunto set my hand and seal, the day,
year and place above written.

Doc. No. ________;


Book No. ________;
Page No. ________;
Series of 2019.

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