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Camacho and Associates

Suite 1605, Corporate 88 Center Building


Paseo de Roxas cor. Sedeño St., Salcedo
Village
Attorneys-at-law 1227, Makati City, Philippines

Telephones : 836-
1351/1620
Web Address:
www.camacholaw.net
Email Address:
atty_camacho@yahoo.com

25 March 2013

MR. BENJAMIN S. BARTOLOME


152 Swallow Drive
Greenmeadows, Quezon City

Subject: FINAL DEMAND TO RETURN MONEY, DOCUMENTS


 US$2 Million
 Safe Keeping Receipts for Gold Deposits in various banks
 Land Titles, Other Vital documents.
Sir:

We write in behalf or our client, MS. VIOLETA YULO ENRIQUEZ ESPINEDA, to


demand for the immediate return of the US$2 Million, Safe Keeping Receipts
(SKR) for Gold Deposits in different banks, and land titles.

You late father, ATTY. DIOGENES B. BARTOLOME, as then lawyer of our client,
had the bounden duty to preserve and protect the interest of our client. Contrary
thereto, it appears that your father took advantage of his position, deceived,
hoodwinked and defrauded our client. After enticing our client in 2001 to sign a
grossly lopsided and grossly inequitable contract, you father disappeared and
surfaced only in 2008.

The US$2 Million belonging to our client, was surreptitiously diverted and
deposited to your father’s account, without her consent. The SKR entrusted to
your father, have not been returned despite demands. The land titles held in trust
by your father and promised to be delivered to our client, have not been delivered
up to now. What were delivered were xerox copies.

We have no doubt that the crime of estafa was committed. We therefore hereby
make this final demand that you immediately return – (i) US2$ Million; (ii) All SKR
for Gold Deposits with BSP, HSBC, Winglung Bank; Citibank, etc.; and, (iii) all land
titles obtained by your father, in trust for our client.

We trust that you will heed to this legitimate demand. You can get in touch with
us anytime for any arrangement you may wish to make. Make no mistake of our
firm determination to exhaust every legal arsenal to protect the interest of our
client. If we do not hear from you within 10 days from notice, we shall take it
that you chose to force us to go to court. Then so be it! We shall immediately file
criminal and civil cases against you, and all members of the Bartolome family,
without further notice. We shall immediately proceed to attach your house,
which was purchased from the proceeds of our client’s money.

Very truly yours,

MANUEL N. CAMACHO

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