Affidavit Parulan

REPUBLIC OF THE PHILIPPINES )
QUEZON CITY ) S. S.
AFFIDAVIT
I, MARY JOY PARULAN, Filipino, of legal age, with office address at 408
1520 JR Building Quezon Ave, South Triangle Quezon City, after having been
sworn to in accordance with the law hereby depose and state that:
1.) That I personally know the complainant Allan Montes Herrera as

he is the Chief Executive Officer (CEO) and Business Owner of
LOADI360 MARKETING SERVICES (hereinafter referred to as
“LOADI360”) a business duly organized and existing under and by
virtue of the laws of the Republic of the Philippines with principal
address at 408 1520 JR Building Quezon Ave, South Triangle Que-
zon City;
2.) That I personally know the respondent Mr. Erdie V. Barela “a.ka.
Kenerdz Valle” as a member-affiliate of the system Loadi360;
3.) That I am the Operations Manager of LOADI360;
4.) That sometime in October 2018, I was informed that various sup-
posed pay ins from purchase of activation codes were not remit-
ted by respondent Barela;
5.) That after I received the said information from the CEO/Owner of
Loadi360, we conducted a system audit on Loadi360 to verify the
veracity of the said report;
6.) That based on the system audit, it was discovered that respon-
dent Barela encoded various names of dealers and as a result var-
ious codes were referred to respondent Barela using the alias
“Kenerdz Valle”;
7.) That the system audit further revealed that the advance payouts
that were supposed to be as personal payouts to the dealers/
member-affiliates were not remitted to the latter by respondent
Barela;
8.) That it was further discovered that the cash advances made by re-
spondent Barela for payment to accounts encoded were also not
realized and was used for the personal credit of respondent
Barela;
9.) That during the system audit it was also discovered that there
were fraudulent accounts that were encoded by respondent
Barela in the system of Loadi360 and there were no deliverables
made to the business;
10.) That during the system audit it was also discovered that respon-
dent to acquire cash advances from the complainant used these
fraudulent accounts;
Complaint-Affidavit
Page 2 of 2
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11.) That during the system audit it was further discovered that the
cash advance made by respondent Barela to be used as compen-
sation for the services done by the Web Developer of Loadi360
were not given to Daryl F. Legion. As a result, the complainant
was obliged to release a separate fund in order to compensate the
services made by Mr. Legion;
12.) That during the system audit it was further discovered that re-
spondent Barela also used the system of Loadi360 for his own
business Droidjo Digital without prior consent and knowledge
from the complainant and without the payment of royalty fees to
Loadi360;
13.) That during the system audit it was also discovered that respon-
dent Barela used the load wallet of Loadi360 in the promo of
Droidjo for its new members without prior knowledge of com-
plainant and without any remittance and/or payment made to
Loadi360;
14.) That several demands were made by complainant Herrera against

Barela. Despite the repeated demands, respondent Barela persis-
tently refuses and fails to return or account for the amounts re-
ceived in trust, to the damage and prejudice of Loadi360;
15.) That respondent Barela used fictitious social media accounts and
posted malicious claims and posts both in the official page of
Loadi360 and with my personal facebook account to besmirched
the business name and reputation of Loadi360;
16.) That I am executing this affidavit to attest the truth of the forego-
ing facts and for whatever purposes this may serve.
AFFIANT FURTHER SAYETH NAUGHT.
IN WITNESS HEREOF, I have hereunto affixed my signature this ____ day

of ___________ 2019 at Quezon City.
MARY JOY PARULAN

Affiant
SUBSCRIBED AND SWORN to before me this ____ day of ______ at

__________________________. Affiant exhibiting to me his/her Government Issued ID. with
ID No. ___________________ issued on _________________ at ____________________________.
Doc. No.
Page No.
Book No.
Series of __

Affidavit Parulan

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REPUBLIC OF THE PHILIPPINES )

1.) That I personally know the complainant Allan Montes Herrera as

3.) That I am the Operations Manager of LOADI360;

14.) That several demands were made by complainant Herrera against

AFFIANT FURTHER SAYETH NAUGHT.

IN WITNESS HEREOF, I have hereunto affixed my signature this ____ day

MARY JOY PARULAN

SUBSCRIBED AND SWORN to before me this day of __ at

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