'.

REPUBLIC OF THE PHILIPPINESREGIONAL TRIAL COURT

THIRD ·JUDICIAL REGIONBRANCH 72OLONGAPO CITY

MY CYBERSTAFF, INC.herein represented by itsPRESIDENT, MURTO NEL,

Plaintiffr

-versus- S . E . C. CASE NO. 15 - 0 0 3

~ -~t:--~~ ROY LEONARD ANDERSONAND PERSONS ACTING ONBEHALF OF MY CYBERSTAFF, INC.WITHOUT AUTHORITY,

Defendants.x-------------~-------------------x

FORMAL OFFER OF EVIDENCE

•..PLAINTIFF, through the undersigned counsel,

unto the Honorable Court" most respectfully filesthis FORMAL OFFER OF EVIDENCE for marking andadmission of the following:

. EXHIBIT "A" - MCS BOARD RESOLUTION NO. 40

• To prove that Murto Nel is authorizedto file a case against the Defendantsand to represent, sign for and inbehalf of the Plaintiff.

EXHIBIT "B" TO "B-16" - CERTIFICATE OFINCORPORATION OF MYCYBERSTAFF, INC.

• To prove that ~y Cyberstaff, Inc.corporation duly existingregistered under Philippine Laws.

lS aand

EXHIBIT "C"

EXHIBIT "D"

-- EXHIBIT "E"

EXHIBIT "F"

.EXHIBIT "G"

EXHIBIT "H"

EXHIBIT "I"

1

- BOARD RESOLUTION NO.2, SERIES OF2014

• To prove that MURTO NEL is thePresident of My Cyberstaff, Inc.

- STOCK PURCHASE AGREEMENT DATEDDECEMBER 15, 2014

Ba~tiaan Johanneswas the o~ner ofMy Cyberstaff, Inc.

he has validlyshares from the

• To prove thatArnoldus Derksen6,500 shares from(MCS) and that

purchased the saidcorporation.

- STOCK PURCHASE AGREEMENT DATEDJANUARY 6, 2015

• To prove that Murto Nel purchased the250 shares in MCS of Gregory IanAnderson.

- STOCK PURCHASE AGREEMENT DATEDJAN. 6,2015

• To prove that Murto Nel purchased the250 shares in MCS of Peiling Xiong.

- LETTER DATED MAY 19, 2015 fromTARA ENERGY, LLC

• To prove that the Defendant, RoyAnderson, has committed acts which areinimical and detrimental to MCS.

- BOARD RESOLUTION NO. 27

• To _ prove that the Plaintiff hasalready dismissed the Defendant as itsChief Financial Officer.

- LETTER DATED MAY 19, 2015 AngloAsian Commodities Corp.

• To proveexistingLaws.

that thecorporation

Plaintiff is anunder Philippine

• To prove that the Defendant has beenunlawfully interfsring with thebusiness of the Plaintiff and hasunilaterally revoked the contract oflease of the Plaintiff with AngloAsian Commodi ties Corp. without aproper Board Resolution.

E;XHIBIT "J" - SECURITIES AND EXCHANGE COMMISSIONGENERAL INFORMATION SHEET OF MYCYBERSTAFF, INC.

EXHIBIT "K" - LETTER DATED AUGUST 19, 2015

• To prove that the Defendant has beenunlawfully interfering with thebusiness of the Plaintiff and isillegally representing himself to bethe President of MCS.

EXHIBIT "L" - LEGAL NOTICE IN MCS WEBSITE DATEDAUGUST 22, 2015

• To prove that the Defendant hasusurped the website of the Plaintiffas well as the telephone numbers,electronic mail addresses and otherintellectual property of thePlaintiff.

EXHIBIT "Mil to "M-3"- EXTRACT FROM POLICE BLOTTERDATED AUGUST 22, 2015

• To prove that the Plaintiff exhaustedall- remed.ir s to. prevent the Defendantfrom stealing the property of thePlaintiff, but to no avail.

EXHIBIT "N" - AFFIDAVIT IN SUPPORT OF THE

1.

ISSUANCE OF THE EX PARTE TEMPORARYRESTRAINING ORDER AND WRIT OFPRELIMINARY INJUNCTION

• To prove the facts necessary for theissuance of a Writ of PreliminaryInjunction and/or TemporaryRestraining Order.

EXHIBIT "0" - JUDICIAL AFFIDAVIT OF MURTO NEL

• To serve as histestimony.

direct examination.

EXHIBI'.r"P" - STOCK AND TRANSFER BOOK

• To prove the current stock owne rshipof My Cyberstaff, Inc.

EXHIBIT "Q" to "Q-l" - STOCK CERTIFICATE OFBASTIAAN JOHANNESARNOLDUS DERKSEN

• To prove his ownership of shares inMes.

EXHIBIT "R" to "R"-3" - STOCK CERTIFICATEOF MURTO NEL

EXHIBIT "T" - STOCK CERTIFICATE OF SALVACION T.VILLALOBOS

• To prove his ownership of sharesin MCS.

EXHIBIT "S" - STOCK CERTIFICATE OF LAURA JANENEL

• To prove her ownership of shares inMCS.

~

• To prove her ownership of shares InMCS.

EXHIBIT "U" - STOCK CERTIFICATE OF CORNELISRONALD BOSMAN

• To prove his ownership of shares InMCS.

EXHIBIT "V" - STOCK CERTIFICATE OF ROY LEONARDANDERSON

• To prove his ownership of shares InMCS.

EXHIBIT "w" - GENERAL INFORMATION SHEET

• To prove the ownership of shares InMCS.

EXHIBIT "X" TO "X-7" - BPI FOREIGN CURRENCYSAVINGS PASSBOOK

• To prove thatdeposited thePhpl,OOO,OOO;OO toas payment for his

Bastiaanamount

the account of6,500 shares.

Derksenof

MCS

EXHIBIT "Y" to "Y-l" DOCUMENTARY STAMPTAX RETURNand LAND BANK OFPHILIPPINES BIRPAYMENT DEPOSIT SLIP

THETAX

• To proveregardsDerksen.

thethe

paymentshares

ofof

taxes asBastiaan

Wi th the' submission and the admission of theabove evidence together with the oral testimony ofplaintiff, the plaintiff rests its case.

ATTY. BART DALANGINCounsel fo~ the DefendantsSan Felipe, Zambales

lOC tol~yG\lr( o..]Ufrc: :u'I ~crr' 7-p Ii'

~

1Olongapo City, 28 September 2015.

RESPECTFULLY SUBMITTED.

Coun or tfie p(aintijJUnit 5 Caby Commercial

94 Magsaysay Driv Olongapo CityMobile No. 0917-8 6174

ROLL NO. 62109~ -916455/01ongapo Cit /01.06.15

IBP No. 9317J . y/01.07.15Admitted to the Bar on April 2013

~

Copy furnished: (private courier)(Explanation: By reason of distance and lack of manpower)