[February 10, 2016]

De Guzman Law and associates

104 VaLencia Hills, N. Domingo street cor. Donya P Juana,
San Juan, Philippines
Tel no. 09178239298
----------------------------------------------------------------------------------------------------------------------------------------To Mr. Mark San Juan,
Good day. Our law firm represents our client Ms. Arnelie Alpajaro. If you are
represented by legal counsel, please direct this letter to the latter immediately and please
notify us of such representation.
You are hereby directed to:
CEASE AND DESIST ALL DEFAMATION OF
Ms. Arnellie AlpajaroS CHARACTER AND REPUTATION.
Our client has established the fact of her reputation and respected business woman
in the community. She has spent years serving the community with her business (DECAL
republic) and contracting projects regarding car show events and many other side projects.
She was considered of having positive reputation by considering others, providing people
jobs or projects which our client generously share including you Mr. Mark San Juan as she
validly concluded in the narration of her statements to this law firm. Ms Alpajaro has learned
that you have engaged in spreading false, destructive, and defamatory rumors about her
which were strongly stated by friends, colleagues and co-workers.
Under the Revised Penal Code, it is unlawful to engage in defamation of anothers
character and reputation. Oral Defamation consists of a statement that tends to injure
reputation which is communicated to another; and that the speaker knew or should have
known to be false.
Accordingly, we demand that you immediately cease and desist your unlawful
defamation of our client Ms. Arnelie Alpajaro and provide us with prompt assurance that you
will cease and desist from further defamation of our clients character and reputation. We
hold evidence in a form of statements made by her friends and colleagues, and they have
guaranteed us that they will make affidavits to strongly support the claim of our client. If for
one instance that our client would still knew of any fact regarding your actions against her
by means of your persistent goal of spreading false statements which would most likely tend
to injure her reputation, then we will file the necessary criminal charges against your person.
If you do not comply with this cease and desist, Ms Arnellie Alpajaro is entitled to
seek monetary damages and equitable relief for your defamation. In the event you fail to
meet this demand, please be advised that our client has asked us to communicate to you
that she will pursue all available legal remedies, including seeking monetary damages,
injunctive relief, and an order that you pay court costs and attorneys fees. Your liability and
exposure under such legal action could be considerable. My client wished to give you one
opportunity to discontinue your illegal conduct by complying with this demand.
Sincerely,

Atty. Pristine De Guzman

De Guzman Law and associates