'.
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)