DE LIMA LAW OFFICE

6 Col. Martinez, St., Sta. Cruz, Quezon City

02-8-374-50-97
0923-247-4851
7 February 2024

TO: LARRY A. LEE

United States of America Air Force
(“USAF”)

RE: Reply to Larry A. Lee’s e-mail sent with

intention to besmirch the reputation of
the deceased spouses Ely A. Lee and
Purita M. Lee.

Gentlemen:

I am the legal counsel of Arlene M. Lee, the first grandchild of

spouses Jose Dypuaco Lee and Albina Alarcon Lee, and the first child of
spouses Ely A. Lee and Purita M. Lee. I am Arlene M. Lee’s youngest son,
and as such, representing her in a very personal capacity.

This Letter was written upon the instruction of Arlene M. Lee after
she read your e-mail to other members of the Lee family with the alleged
purpose of “to share and shed light on some information [the Lee family]
may not know that hopefully strengthens [the] peace and love within [the
Lee family]” but the ultimate substance of which is to darken the
reputation of the already deceased spouses Ely A. Lee and Purita M. Lee.

At the onset, Arlene M. Lee is amiss as to your real purpose as to why

you are sending such e-mail, a copy of which is attached hereto as Annex
“A”, after all these years. Is it because you wanted to disfigure, delete and
re-write what actually transpired in the olden days within the confines of
Jose Dypuaco Lee’s home? Most of the people who know the truth have
already passed away, and as such, this is the perfect time for you to distort
the facts to cover-up the stench of all the unjust treatment which Arlene M.
Lee, her mother (i.e., Purita M. Lee), and her siblings have suffered from
the Lee family.
 DE LIMA LAW OFFICE
6 Col. Martinez, St., Sta. Cruz, Quezon City
02-8-374-50-97
0923-247-4851
So that it will be clear, Ms. Arlene M. Lee did not ask for this Letter to
humiliate you. All she intends is to make things clear, and educate and
inform everyone in the Lee family, whether he or she be of the younger or
older generation, of what she actually witnessed growing up in the house
of spouses Jose Dypuaco Lee and Albina Alarcon Lee, which are contrary
to all you have stated in your e-mail. Further, this Letter is written to clear
the reputation of Ely A. Lee, and especially, Purita M. Lee, the head of our
so called “Addams family” who you never accepted in the Lee family, and
whom the Lee family constantly subjected to humiliation and
discrimination, even until now that she is already resting in heaven.

On this note, Ms. Arlene M. Lee would like to remind you that she is
of the same age as you (i.e., seventy (70) years old) since you were both
born in 1953. Considering this, you and Ms. Arlene M. Lee grew up as if
you were brothers and sisters, although you are a generation ahead by
blood. In fact, growing up, Ms. Arlene M. Lee was considered the youngest
daughter of her grandparents, who are your parents, spouses Jose Dypuaco
Lee and Albina Alarcon Lee. Accordingly, whatever it is that you allegedly
saw, heard, tasted, smelled and felt in the 60s, 70s and 80s concerning the
Lee family, Ms. Arlene M. Lee also saw, heard, tasted, smelled and felt it
back then.

Let us start with your allegation that spouses Jose Dypuaco Lee and
Albina Alarcon Lee gave a market store to Ely A. Lee. The same is true.
Arlene M. Lee does not deny it. However, the store you are pertaining to
was given as a wedding gift to spouses Ely A. Lee and Purita M. Lee
considering that they got married at a young age before turning twenty
(20) years old, and as such, were merely starting off with their independent
lives. Further, you should remember that the store given to Ely A. Lee was
a very small store in the Iriga City Market. It was Purita M. Lee who made
it flourish to a huge and profitable business through her business acumen,
which apparently most of you in the Lee family do not possess despite
having a Chinese blood. And even if you were to argue before us that the
store given to Ely A. Lee represents capital advanced from the Lee family,
such debt was paid by Ely A. Lee ten folds. You must remember that Jose
Dypuaco Lee had illegitimate children who resided in Baao, Camarines
 DE LIMA LAW OFFICE
6 Col. Martinez, St., Sta. Cruz, Quezon City
02-8-374-50-97
0923-247-4851
Sur. When Jose Dypuaco Lee went to the United States of America
(“USA”), it was Ely A. Lee who continued supporting such extended
family members. The amounts advanced by Ely A. Lee are more than
enough to cover the small capital which the small store had when it was
given to him. If you want, we can present before you such illegitimate
children to personally tell you that it was Ely A. Lee who supported them
while Jose Dypuaco Lee was abroad. In fact, such illegitimate children will
even tell you that, in one occasion, they tried approaching your legitimate
sister, Shirley Lee Trinidad, and asked for support but they were simply
brushed away by the latter since she does not recognize them as her
siblings.

Unfortunately, the store given to Ely A. Lee by spouses Jose Dypuaco

Lee and Albina Alarcon Lee was destroyed after a massive fire erupted in
the Iriga City Market. Despite this, Ely A. Lee and Purita M. Lee ventured
in or acquired more businesses and properties such as the present
LEMARS Hotel, a wholesaler store, and various apartments, among others.
They were able to do this without receiving any support from the Lee
family. These businesses were built and properties were acquired through
the sheer determination of Purita M. Lee, and through the employment of
her most famous adage that to succeed in life, you must possess three (3)
distinct qualities, namely: “ATENDIDO”, “PURSIGIDO” and
“DETERMINADO”. Arlene M. Lee even remembers the time that when she
was assisting Purita M. Lee in managing the businesses, she would see
Purita M. Lee using worn-out underwear (i.e., her bra is simply held using
an imperdible or pin) since she was very concentrated in managing the
businesses and was thrifty in managing her capital to ensure the success of
the businesses, and accordingly, to ensure that all of her nine (9) children,
including Arlene M. Lee, would go to good schools and receive proper
education.

With respect to your allegation that spouses Jose Dypuaco Lee and
Albina Alarcon Lee sold most of their properties to Shirley Lee Trinidad
because Jose Dypuaco Lee needed funds to pay the medical expenses of her
previous wife in China, the same is untrue. I particularly heard Ely A. Lee
talking to Purita M. Lee during a lunch time conversation that Ely A. Lee
 DE LIMA LAW OFFICE
6 Col. Martinez, St., Sta. Cruz, Quezon City
02-8-374-50-97
0923-247-4851
was asked by Jose Dypuaco Lee to take over his businesses and properties
while he is in the USA. Ely A. Lee then turned down such proposal. He
explained to Jose Dypuaco Lee that he already has a lot of businesses and
properties, and if he will also assume Jose Dypuaco Lee’s businesses and
properties, he will be targeted by the tax collectors. After being turned
down by Ely A. Lee, Jose Dypuaco Lee then decided to have a simulated
sale with Shirley Lee Trinidad. In the simulated sale agreement, it will
appear that Shirley Lee Trinidad paid for Jose Dypuaco Lee’s businesses
and properties although no such payment actually occurred. It was simply
for the sole purpose of transferring the businesses and properties to Shirley
Lee Trinidad’s name while Jose Dypuaco Lee is in the USA to ensure that
such businesses and properties can still be managed properly. However, in
substance, the ownership of such businesses and properties remained with
Jose Dypuaco Lee and Albina Alarcon Lee.

The trouble arose when Jose Dypuaco Lee passed away. When that
occurred, Ely A. Lee asked Shirley Lee Trinidad to surrender Jose Dypuaco
Lee’s businesses and properties so that it may be divided among the
siblings. Shirley Lee Trinidad did not accede to such request. She is now
claiming that the simulated sale was an actual sale, and that in substance,
she actually purchased and is the present owner of the Jose Dypuaco Lee’s
businesses and properties. Ely A. Lee then prepared to file a case against
Shirley Lee Trinidad to recover Jose Dypuaco Lee’s businesses and
properties. Ely A. Lee wanted to file the case not to recover his share in the
businesses and properties of Jose Dypuaco Lee as he had more than
enough to live a comfortable life but to protect the interests of his other
siblings. He was claiming for proper and fair treatment of his other
siblings. Prior to the filing of such case, Shirley Lee Trinidad asked for
Judge Malaya’s intervention. She asked the latter to talk to Ely A. Lee as the
two (2) are close friends. Judge Malaya then relayed Shirley Lee Trinidad’s
offer of a certain amount (i.e., Arlene M. Lee could no longer remember if
the amount was Php15,000.00 or Php10,000.00) to Ely A. Lee in exchange
for no longer pursuing the case he wanted to file against her. Ely A. Lee
then told Judge Malaya that he cannot accepts such offer as he is not
claiming for his share in the inheritance but is claiming for his other
 DE LIMA LAW OFFICE
6 Col. Martinez, St., Sta. Cruz, Quezon City
02-8-374-50-97
0923-247-4851
siblings who stand to be deprived of the fruits of Jose Dypuaco Lee and
Albina Alarcon Lee’s labor.

Unfortunately, Ely A. Lee passed away even before such case was
filed. He was brutally murdered in the warehouse of his store. When Ely A.
Lee died, only three (3) of his children finished their education, namely:
Arlene M. Lee, Jean Lee and Ely M. Lee, Jr. There were still six (6) children
who were still in school, namely: Glenn M. Lee, Joy M. Lee, Ronald M. Lee,
Gina L. Monera, Franco M. Lee and Jeanzie L. Caganda. You must recall
that during Ely A. Lee’s wake, you and your other siblings promised to
assist in the education of the six (6) remaining children who were still
studying at that time. Also, you should recall that you and your other
siblings went with me and Purita M. Lee when we consulted Atty. Vicente
B. De Lima regarding the case to be filed against the person who murdered
Ely A. Lee. During such meeting, you and your other siblings promised to
assist us in the payment of Atty. Vicente B. De Lima’s legal fees. However,
all of these promises were false.

Purita M. Lee was left to fend for her children. It was simply her who
tirelessly worked to ensure that the remaining six (6) children who were
still studying when Ely A. Lee was murdered would finish their studies.
Arlene M. Lee distinctly remembered that Purita M. Lee uttered: “Dawa na
mag-sisinapot ako, basta matapos ko kamo” (i.e., I would sell cooked
bananas in the street just to ensure you finish your educaton). And through
her efforts, I am proud to say that my grandmother, Purita M. Lee,
accomplished her purpose as she was able to produce nine (9) professionals
without any single cent of help from the Lee family, to wit. –

Arlene M. Lee Licensed Medical Technologist

Jean Lee Licensed Nurse
Ely M. Lee, Jr. Computer Engineer
Glenn M. Lee Civil Engineering Graduate
Joy M. Lee Licensed Dentist
Ronald M. Lee Commerce Graduate
Gina L. Monera Licensed Pharmacist
Franco M. Lee Licensed Physician
 DE LIMA LAW OFFICE
6 Col. Martinez, St., Sta. Cruz, Quezon City
02-8-374-50-97
0923-247-4851
Jeanzie L. Caganda Licensed Nurse / Retired Flight
Stewardess

This accomplishment is of her own and has nothing to do with you at

all.

Further, during the court hearings for the trial of the murder of Ely A.
Lee, it was only Minnie T. Arroyo who assisted our family by being
physically present during such hearings and taking down notes of the
proceedings. While she did not extend financial support, we are very much
grateful to her during those times of despair for serving as a guiding voice
and source of hope. Also, it was only us who paid the legal fees of Atty.
Vicente B. De Lima. You and your other siblings reneged on your promise
of assistance.

Purita M. Lee has experienced a lot of discrimination from the Lee

family. For instance, Shirley Lee Trinidad keeps on telling everyone that
Purita M. Lee has a lot of debt. Indeed, Purita M. Lee had a lot of debt. I
guess Shirley Lee Trinidad is not at all familiar as to how businesses are
run. A basic financial management principle is financial leverage (i.e., it is
best to acquire assets using debt provided that the cost of borrowing can be
paid off by the return of such asset). Moreover, Purita M. Lee has paid all
of her debts and obligations at the time she passed away; thus, there is no
issue at all. More importantly, Purita M. Lee amassed debts to finance her
businesses which she built to pay for the education of her children. She did
not use such funds to buy drugs and become a drug addict.

Even the children of Purita M. Lee suffered from discrimination

emanating from the Lee family. Franco M. Lee was not given a Babe Ruth
chocolate bar because he was too dark to be a member of the Lee family.

The hell with these disdain experiences from the Lee family. At the
end of the day, Purita M. Lee emerged victorious in life. At the time she
passed away, she left a lot of viable businesses and properties which the
generation of our family can enjoy. More importantly, all of her children
are professionals who are living independently. They do not even need the
 DE LIMA LAW OFFICE
6 Col. Martinez, St., Sta. Cruz, Quezon City
02-8-374-50-97
0923-247-4851
businesses and properties left behind by Purita M. Lee to survive this life.
Our family has used all of the bad mouthing and discrimination we
received from the Lee family as motivation to become better in life. We, in
fact, thank you for looking down on us since it served as fuel to further
enhance ourselves.

Nonetheless, it remains that, in writing your e-mail, you intended to

disfigure and blacken the reputation of the deceased Ely A. Lee and Purita
M. Lee. Under Philippine Laws, this serves as a cause of action for us, the
heirs of Ely A. Lee and Purita M. Lee, to file the necessary charges against
you. I wish that we do not reach inconvenient litigation considering that
you are still a relative by blood.

Accordingly, FINAL DEMAND is hereby made upon you to

immediately RECTIFY the misinformation that you tried to spread
through your e-mail and APOLOGIZE in writing within FIFTEEN (15)
days from receipt of this letter. Otherwise, I will be constrained to file the
necessary legal action against you, to protect the interest of my client.

Should you want to pay the amount stated or wish to clarify certain
matters, I may be contacted through the information stated in the heading
of this letter. I trust that you will give this matter prompt and preferential
attention to avoid the expense and inconvenience of litigation.

Very Truly Yours,

Atty. Gregorio L. de Lima III