Republic of the Philippines

REGION III
REGIONAL TRIAL COURT
Iba, Zambales, Branch 70

JANE DOE,
Complainant

versus
CRIMINAL CASE NO. M-17-0678910
For: Estafa or Swindling

DENG XIAO PENG and BO IN LIE,

Respondents.
xx
JUDICIAL AFFIDAVIT OF JANE DOE

I am JANE DOE, of legal age, majority owner/treasurer of Zambales

Mineral Resources Inc. with postal and residence address at 123 Arellano
St., Zone 5, Iba, Zambales. I am being interrogated by Atty. Quinnee S.
Vallejos, at his law office which is located at Barangay Palanginan, Iba,
Zambales. I am executing this affidavit for it to serve as my direct testimony.

I am answering Atty. Vallejos questions truthfully and based on my

personal knowledge knowing fully well that I do so under oath and that I
may face criminal liability for any false testimony.

Q1: Ms. Jane Doe, why did you file this case?
A2: In order to prosecute Mr. Deng Xiao Peng and Bo In Lie for
Estafa or Swindling and to recover actual damages like legal
fees, exemplary and nominal.

Q2: What is the nature of your business?

A2: I am engaged in trading and marketing of minerals consisting of
chromites and nickel?

Q3: What is the name of your company?

A3: Zambales Mineral Resources Inc.

Q4: What is the registering agency of your company?

A4: In SEC. (handing the companys SEC registration and
Constitution and By-laws)

Q5: I am marking this SEC registration that you handed to me as

Annex A and the attached Constitution and By-laws of your

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 company as Exhibit A-1, where is the source of your mineral
ores?
A5: It is primarily sourced from Zambales.

Q6: Who are your shareholders in the company?

A6: Our company has another shareholder, his name is Mr. Mao
Tse Tung and others from the Philippines and China.

Q7: Where is the main market of your companys mineral

commodities?
A7: In China.

Q8: How do you know Mr. Mao?

A8: Mr. Mao has also a company based in China called Mineral
Rich Capital Resources LTD who is sister company of
Zambales Mineral Resources Inc. and source his resources from
my company.

Q9: How do you know Mr. Deng Xiao Peng and Bo In Lie?
A9: They came from China to Zambales to look for chromites
commodities to buy claiming as representatives of Shanghai
Express Mining Co. Ltd and A&A logistics, that both
companies are based in Tianjin, China.

Q10: How do Mr. Deng Xiao Peng and Bo In Lie met Mr. Mao?
A10: They came to know Mr. Mao in the Philippines through the
internet and business contacts.

Q11: What did Mr. Deng Xiao Peng and Bo In Lie, and Mr. Mao do?
A11: Our sister company Mineral Rich Capital Resources LTD
through Mr. Mao entered into a Contract of Sale or Purchase of
Chromites with Mr. Deng Xiao Peng and Bo In Lie.

Q12: What are the stipulations in the contract?

A12: The contract calls for the purchase of 8,000 metric tons.

Q13: How are you related to the transaction between Mr. Deng Xiao
Peng and Bo In Lie met Mr. Mao?
A13: As sister company of my company Zambales Mineral
Resources Inc. was made as second beneficiary of the payment
of the commodity via letter of credit.

Q14: Where is the letter of credit?

A14: This is the contract sir. (handing a copy of contract).

Q15: I am marking this Contract that you handed to me as Annex B,

what happened then after the execution of contract?

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A15: When the 8,000 metric tons of chromites is about to be loaded
in the ship, Mr. Deng Xiao Peng and Bo In Lie suddenly
changed their minds despite of their thorough inspection of the
chromites in Zambales, alleging it being a low quality of
chromites as alibi .

Q16: What did your company do then?

A16: Our companies terminated the said Contract of Sale or
Purchase.

Q17: What did you do then?

A17: Our companies terminated the said Contract of Sale or
Purchase.

Q18: How did you sell or dispose the chromites?

A18: Mr. Deng Xiao Peng and Bo In Lie were able to convince me
and Mr. Mao to sell and ship to them 2,254.20 portions of
metric tons of chromites.

Q19: What have you do to assure that they will buy it?
A19: To make sure that they will not have excuses later on about the
quality of the mineral, I told them to sort out and select the
mineral chromites they want and they did.

Q20: What happened next?

Q20: Then, I shipped the commodity, with their supervision, in the
name of my company Zambales Mineral Resources Inc. on
Cash on Delivery (COD) to China at my expense (handing the
Proofs of Shipment)

Q21: I am marking this Proofs of Shipments that you handed to me

as Annex C, how was the payment made?
A21: Mr. Deng Xiao Peng and Bo In Lie refused to pay the price of
$190.00, U.S. Dollars per metric ton upon receipt of the same
commodity in Qinzhou Port, China.

Q22: What did you do when he failed to tender the payment?

A22: I demanded for payment, both verbal and written, so many
times but they even stated in their answer that our company
might be committing smuggling in China.

Q23: What was your reply to their answer?

A23: We stated in our answer that they are the one who are
smugglers and that we are plain seller in good faith and
compliant with all the requirements of the law in selling the
commodity.

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 Q24: What do they did after u sent reply?
A24: Mr. Deng Xiao Peng and Bo In Lie said that Chinese
departments will put th law office of my lawyer who sent the
letter demand into a black list if my lawyer fails to go to China
as agent of my company.

Q25: What are their other schemes to deceive you?

A25: Mr. Deng Xiao Peng and Bo In Lie demanded for payment of
one million US dollors (handing the copy of the Answer of the
respondents to demand letter)

Q26: I am marking this Answers that you handed to me as Annex D,

for the meantime, I dont have further questions, do you have
any statements to add or take away on this affidavit?
A26: I dont have sir for the meantime.

Q27: Were you threatened, promised or bribed to do this confession?

A27: No sir. I made it voluntarily with my own free will.

Q28: Are you willing to sign this affidavit consisting of six (6) pages,
to certify that all the statements you made are true.
A28: Yes sir.
---------END OF STATEMENT----------

JURAT

IN WITNESS WHEREOF, I hereunto set my hand below this 27th

day of May, 2017 at Atty. Quinnee S. Vallejos Law Office, Barangay
Palanginan, Iba, Zambales, to prove the truthfulness of all my statements
here and also to authenticate the documents which I have turned over to
Atty. Vallejos and which she marked in my presence.

JANE DOE
Affiant

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 SUBSCRIBED AND SWORN to before me this 27th day of May,
2017 at Atty. Quinnee S. Vallejos Law Office, Barangay Palanginan, Iba,
Zambales, affiant exhibiting to me her Passport bearing No. SS12345678
issued on 8/9/12 and expiring on 8/8/17.

NOTARY PUBLIC

Doc No. 29;

Page No. 21;
Book No. 11;
Series of 2017.

ATTESTATION

I hereby state, under oath, that I faithfully recorded the questions I

asked and the corresponding answers that the witness gave and that neither I
nor any other person present or assisting me has coached the witness
regarding the latters statement.

ATTY. QUINNEE S. VALLEJOS

Affiant

SUBSCRIBED AND SWORN to before me this 27th day of May,

2017 at Atty. Shared Liahona Vista, Barangay Palanginan, Iba, Zambales,
affiant exhibiting to me her Drivers License bearing No. 02493594 issued
on 9/9/16 and expiring on 9/9/17.

NOTARY PUBLIC

Doc No. 39;

Page No. 11;
Book No. 21;
Series of 2017.

Copy Furnished:

Office of the Public Prosecutor

Iba, Zambales

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