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A.

Pot

1. In answer to Question 7 of JA, you mentioned that on March 30, 2015, at around 8 am, you
were at Rosana Suarez’s house, is that correct? yes

2. And in Answer to Question 8 of JA, you mentioned that you went to her house to fix a pot,
correct? yes

3. And in Answer to Question 9 of JA, you stated that you left her house at around 1 pm? yes

4. Can you please describe to us the pot that you were fixing at that time? Just a small pot

5. What was the condition of that broken pot? It was divided into four

6. So, it took you five hours just to fix a small pot? No, because after I fixed the broken pot, I
ate lunch with Rosana Suarez and her children. We also took advantage of the time to bond
and update each other with our life’s events.

B. Illiteracy

1. In answer to Question 5 of JA, you mentioned that Rosana had no formal education and
was not given the opportunity to go to school due to poverty? yes

2. In answer to Question 6 of JA, you affirmed that Rosana Suarez is unlettered, correct? yes

3. So, you stated that Rosana was unlettered because she had no formal education? Based
on my observation, yes.

4. Would you agree with me that an unlettered person is someone who is incapable of reading
and writing? (speculative)

5. So, would you agree with me that it is possible for someone to be literate even if she has not
received any formal education? (speculative) (don’t tell KC/Fronda to reform question)
C. Negotiation

1. In relation to Question 14 of JA, you stated that Rosana offered to mortgage her property to
Jolleane Perino? yes

2. Also, in Question 15 of JA, you said that you heard that Jolleane accepted Rosana’s offer of
mortgage? yes

3. Were you aware if there was any Deed of Real Estate Mortgage executed by the Rosana
Suarez and Jolleane Perino? I’m not aware of any.

4. Would you agree with me that it is possible that the parties may have changed their minds
and executed instead a Deed of Absolute Sale? (speculative) (sustain)

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