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G/F GMC Plaza Bldg., LegaspiExtn.corner

M.J. Cuenco Ave., Cebu City
Atty.Valeriano S. Loon
Telefax No.(032)254-0453
Atty. Habeas M. Corpuz

Atty. Juril B. Patio

-----------------------------------------------------------------------------------------------------------Cell. No. 09277504306; email add: juril.patino@yahoo.com

August 11,2015
Mr. Norman N. Lim
Owner/Sole Proprietor
Rabaya St.,Kimba, San Roque,
Talisay City, Cebu
Our client ROBERT VILLANUEVA PEREZ referred to our law office to formally
inform you that he is planning to file criminal action against your driver MARK ANTHONY
RETIZA NOYNAY and a separate civil action for recovery of damages against you as the
owner /operator of the taxi driven by NOYNAY which causes damage on the jeepney driver
driven by our client.
In this regard, our client is open for possible amicable settlement should you pay the
following incurred damages, to wit :
Shop Repair - P 12,000.00 (See Attached quotation)
Boundary Fee P500 per day for 11 days (From July 31-August 10,2015 = P5,500
Drivers Daily Take Home Pay 1000 X 11 days = P 11,000.
We are also informing you that because of your adamant refusal to honor our clients
demands, they incurred liabilities for hiring the services of a lawyer whose
acceptance/engagement fees is FIVE THOUSAND PESOS (P5,000) exclusive of appearance
and other litigation costs in the future. Hence, the acceptance fees shall form part of your
aggregate liabilities.
We are giving five (5) days from receipt of this demand letter to pay the following should
you wish to relieve yourself from any liability as arising from the reckless driving of your
employed driver which causes damages.
We hope that you will give utmost consideration and attention on this matter.

Very truly yours,

Atty. Juril BrokaPatio
Received by : _________________________________
: _________________________________