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September 27, 2014

Atty. Apple Licuanan


Pearson Hardman
Suite 123, Corporate Center
Mayapis St., Makati

Dear Atty. Licuanan,

This is in reference to your letter dated 23 September 2014 regarding the


demand for to vacate the Apartment Unit denominated as Apartment C, located at
287 E. Jacinto corner Del Pilar Steet, South Cembo, Makati City addressed to our
client, Ms. Michelle Marie Banes and her family.

We understand that our client failed to observe the thirty day notice that
Protect Security and Investigation Services Company, Inc. has given and refusing
to do such demand.

However, our client cannot be subject to such demand for under the Contract
of Lease executed between Ms. Banes and your client, the lessor cannot force the
lessee to vacate the property without giving her a prior notice of at least two (2)
months. For your better understanding of the circumstances herein disputed, two
(2) months is understood to be approximately Sixty (60) days. In this regard, you
cannot compel our client to easily vacate the Apartment Unit for it is her right upon
the leased premises and it was your client on the first place that caused the breach
of Contract and was not able to do the legal obligation under the agreement.

Your client’s failure to comply with the provision of the Contract shall give
our client the right to stay in the above-mentioned apartment unit. Hence, your
Final Demand addressed to our client cannot be taken into consideration and is
considered null and void.
Very Truly Yours,

Licuanan & Licuanan Law


By:

AJ Licuanan
Managing Partner

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