AFFIDAVIT OF COMPLAINT

I, MELVIN S. ALMORO, of legal age, Filipino and with business address

at #8002 Old National Highwat, Barangay Balibago, Santa Rosa City, Laguna after
having sworn in accordance with law herby depose and state that:

1. I am the legal representative and Head of Marketing, Loan and Collection

Group of AccuTrust Lending Corporation;
2. On September 1, 2021, defendant Michael Pagar and Jarrah Maria N. Pagar
entered into a loan agreement towards AccuTrust Lending Corporation
wherein they will borrow an amount ONE HUNDRED THOUSAND
PESOS (Php 100,000) payable in 12 installmentS;
3. In the Promissory Note and Disclosure Statement on Loan, Defendant
MICHAEL PAGAR shall be the principal borrower while JARRAH
MARIA N. PAGAR shall act as Co-Maker;
4. Defendant Michael Pagar issued post-dated checks in favor of AccuTrust
Lending to secure their loan obligation;
5. The post-dated checks issued by Defendant Michael Pagar bounced when
deposited in our depositary bank;
6. Defendants Almine and Landrito failed to settle their remaining balance
towards AccuTrust Lending Corporation;

7. On February 10, 2023, a Notice of Final Demand thru our counsel Atty.
Rolan Jeff A. Lancion was served thru registered mail towards the
residential address of Defendants Pagar at 15F, Katipunan Ave., California
Village. Brgy. San Bartolome, Novaliches, Quezon City/ Blk 3, Lot 2, Titus
St., West Fairview, Quezon City;

8. I am executing this Affidavit to attest the truth of the foregoing and for all
legal intents and purposes it may serve.

IN WITNESS WHEREOF, I have hereunto set my hand 29 th day of March 2023

at Binan City, Laguna.

___________________
MELVIN S. ALMORO
Affiant
SWORN AND SUBSCRIBED to before me this ____ day of ___________,
2023 the affiant personally appeared and exhibited his competent evidence of
__________.

Doc No. ________;

Page No. ________;
Book No. ________;
Series of 2023.