Republic of the Philippines) In the City of Davao - - - - - -)s.s.

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AFFIDAVIT OF WITNESS I, Nathalie Ayala, Filipino, of legal age, with address at #27 Coral Street, Marfori Heights, Davao City, after being sworn to in accordance with law, hereby state as follows: 1. That I am the mother of Jason Ayala, the victim; 2. That the victim is living with me; 3. That I have known the accused for almost four years; 4. That I have been doing several business transactions with the accused for almost four years; 5. That the accused have been in my office several times for almost four years; 6. That around 1pm on December 20, 2012, I received a call from my maid telling me that she and Jason are kidnapped and that the kidnappers want 10 Million for their release and that they will call again for the pay off; 7. That after the call I informed the police authorities of the kidnapping; 8. That around 2pm they have called again, this time it was a male voice, I negotiated for a lower ransom but they turned down my offer; 9. That the third call was around 2:30pm, and it was from a different male voice; 10. That the voice from the third caller, sounds like the voice of the accused; 11. That we have finally settled the ransom for 1.5Million; 12. That I offered to pay 1,320,000.00 in cash and the remaining will be paid in kind which consists of jewelries and a pistol; 13. That the caller told me that they will call again for the pay-off site; -1-

14. That on the fourth call at around 3pm, the voice was from a male voice but different from the second and the third caller; 15. That the fourth caller told me that the pay-off site will be at a resto bar at Quimpo Boulevard at 9:45pm; 16. That he instructed me to place the ransom inside a bag and put it in the trunk of my car and left the trunk unlocked, and to walk away for ten minutes without turning back; 17. That after the call, I informed the police authorities the place and time of the pay-off site; 18. That upon arrival at the site, I performed the things that was instructed to me by the caller; 19. That after 10mins. I was informed through phone call that my son and my maid were already at a cemetery in Sasa; 20. That upon knowing the location of my son, I immediately informed the police and they instructed me not to go back to the pay-off site but instead proceed to Sasa Police Station and to wait there; 21. That after waiting for several minutes my son and his nanny arrived in a patrol car. IN WITNESS HEREOF, I hereby affixed my signature on this 31 st of May, 2013 at Davao City, Philippines.

Nathalie Ayala Affiant

SUBSCRIBED AND SWORN before me this 31st of May at Davao City, Philippines.

Raul Bendigo Investigating Prosecutor -2-