COMPLAINT IN FORM OF CLASS SUIT

H, I, J, K ,L M,N AND O, on their own

Behalf and on behalf of class members,

Plaintiffs,

-versus- Civil Case No. 12345

Juan dela Cruz, John Manuel

Princess Cabro, and ABC Voluntary Association,

Defendants

x x

Plaintiffs are legal age and are members of the voluntary association, known as XYZ
Voluntary Association, which is composed of over 500 members, who are required to contribute
P200.00 monthly, in return for the benefits extended to its members. Plaintiffs are suing on their
own behalf as members of said association and on behalf of all other members thereof, who are
so numerous that it is impracticable to implead them all as plaintiffs.

Defendants, as officers of said corporation, have mismanaged its affairs, did not render
any accounting to the members, and appropriated the members’ contributions unto themselves,
thereby compelling the members thereof to compel said officers to wind up the affairs of the
association and to require defendants as officers thereof to render an accounting of the money
and property of the association.