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CGRLAW & Associates

5F First Global Building, 122 Gamboa Street
corner Salcedo Street, Legaspi Village, Makati City
Tel. No. (+63 2) 985 4322
email: claude.requino@cgrlaw.ph

            info@cgrlaw.ph

website: http://www.cgrlaw.ph

This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. You are hereby notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited

RE-STAMPING OF NEW VISA IMPRINTS IN THE PASSPORTS OF FOREIGNERS GRANTED RESIDENCY UNDER REPUBLIC ACT (RA) NO. 7919 OR THE ALIEN SOCIAL REGISTRATION ACT OF 1995

Bureau of Immigration (BI) Commissioner Siegfred B. Mison issued Operations Order No. SBM-2014-035 dated 18 August 2014 providing guidelines in the re-stamping of new visa imprints in the passports of foreigners' granted residency status under RA 7919, as amended by RA No. 8247.

Holders of old RA 7919 visa imprints in their valid passport or other travel document shall report to the BI Main Office, RA No. 7919 Unit, for the re-stamping of the new RA No. 7919 visa imprint. The period of compliance shall commence on 15 SEPTEMBER 2014 and end on 15 DECEMBER 2014.

CGRLAW & Associates

5F First Global Building, 122 Gamboa Street
corner Salcedo Street, Legaspi Village, Makati City
Tel. No. (+63 2) 985 4322
email: claude.requino@cgrlaw.tk

            info@cgrlaw.tk

website: http://www.cgrlaw.tk

This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. You are hereby notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited.

Does the Employer has the Burden of Proof to show Payment of Overtime Pay and Other Money Claims?

It has always been argued that the Employer must show proof that the employee has been duly paid of his money claims since it has in its possession proof of such payments, and in the absence of proof to the contrary, it is deemed that no payment has been made.

This contention is correct provided that the employee had already established that it is entitled to such benefits or claims. Simply put, the employee must first establish his allegation (Godofredo Morales v. Skills International Company, G.R. 149285).

In the case of Romeo Lagatic v. NLRC, G.R. 121004, January 28, 1998, the Court ruled that the employee failed to show his entitlement to overtime and rest day pay, due to lack of sufficient evidence as to the number of days and hours when he rendered overtime and rest day work. Entitlement to overtime pay must first be established by proof that said overtime work was actually performed, before an employee may avail of said benefit. To support his allegations, the employee submitted in evidence minutes of meetings wherein he was assigned to work on weekends and holidays at Cityland'd Housing projects. Suffice it to say that said minutes do not prove that the employee actually worked on said dates. It is basic rule in evidence that each party must prove his affirmative allegations.

In another cases, the court denied the claim since there were no proof adduced to show entitlement.

The employees never produced any proof of actual performance of overtime work (Julio Cagampan v. NLRC, G.R. No. 85122-24, March 22, 1991). As for the employee's claim for overtime pay, it must be denied, for other than the uncorroborated affidavits of her colleagues, there is no concrete proof that she is entitled thereto. And so must her claim for allowances, no proof to her entitlement thereto having been presented (Lilia P. Labadan v. Forest Hills Academy, G.R. No. 172295, December 23, 2008).

In the recent decided case this January 16, 2012, Abduljuahid R. Pigcaaulan v. Security and Credit Investigation, Inc., G.R. No. 173648, the Court reversed the decison of the Labor Arbiter and the NLRC and declared that "The handwritten itemized computations are self-serving, unreliable and unsubstantial evidence to sustain the grant of salary differentials, particularly overtime pay. Unsigned and unauthenticated as they are, there is no way of verifying the truth of the handwritten entries stated therein. Written only in pieces of paper and solely prepared by Canoy and Pigcaulan, tehses representatives daily time records, as termed by the Labor Arbiter, can hardly be considered as competent evidence to be used as basis to prove that the two were underpaid of their salaries. We find nothing on records whch could substantially support Pigcaulan's contention that he had rendered service beyond eight hours to entitle him to overtime pay and during Sundays to entitle him to restday pay. Hence, in the absence of any concrete proof that additional service beyond the normal working hours and days had indeed been rendered, we cannot affirm the grant of overtime pay.

Payment to Employees on Suspension due to Inclement Weather like Typhoon

PAYMENT OF WAGES FOR PRIVATE SECTOR EMPLOYEES DUE TO INCLEMENT WEATHER OR NATURAL CALAMITIES

All private sector employees are advised of the following rules for pay on suspension of work due to typhoon.

A. IF UNWORKED

• NO PAY, unless there is a favourable company policy, practice or collective bargaining agreement (CBA) granting payment of wage on said day; and
• When the employee has accrued leave credits, he may be allowed to utilise such leave so that he will ave compensation on said days.

B. IF WORKED

• NO ADDITIONAL PAY is given to the employees but only their salary on said day.

Although it is NO WORK NO PAY, to alleviate the plight of employees in times of crisis, the employers may provide such extra incentives or benefits to employees who reported for work.


*Labor Advisory 10, s. 2013

CGRLAW & Associates

5F First Global Building, 122 Gamboa Street

corner Salcedo Street, Legaspi Village, Makati City

Tel. No. (+63 2) 985 4322/  (+63 2) 889 5210

Mobile: +63 918 948 6092

email:claude.requino@cgrlaw.tk

info@cgrlaw.tk

website: http://www.cgrlaw.tk

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List of Holidays for 2015, declared by virtue of Proclamation No. 831, s. 2014

The following is a list of holidays for 2015, declared by virtue of Proclamation No. 831, s. 2014, unless otherwise specified:

January 1, 2015, Thursday – New Year's Day (Regular holiday)

January 2, 2015, Friday - Additional special non-working day (Special non-working day)

February 19, 2015, Thursday – Chinese New Year (Special non-working day)

February 25, 2015, Wednesday – EDSA Revolution anniversary (Special holiday)

April 2, 2015, Thursday – Maundy Thursday (Regular holiday)

April 3, 2015, Friday – Good Friday (Regular holiday)

April 4, 2015, Saturday – Black Saturday (Special non-working day)

April 9, 2015, Thursday – Araw ng Kagitingan (Regular holiday)

May 1, 2015, Friday – Labor Day (Regular holiday)

June 12, 2015, Friday – Independence Day (Regular holiday)

August 21, 2015, Friday – Ninoy Aquino Day (Special non-working day)

August 31, 2015, last Monday of August – National Heroes Day (Regular holiday)

November 1, 2015, Sunday – All Saints Day (Special non-working day)

November 30, 2015, Monday – Bonifacio Day (Regular holiday)

December 24, 2015, Thursday - Additional special non-working day (Special non-working day)

December 25, 2015, Friday – Christmas Day (Regular holiday)

December 30, 2015, Wednesday – Rizal Day (Regular holiday)

December 31, 2015, Thursday – Last day of the year (Special non-working day)

CGRLAW & Associates

5F First Global Building, 122 Gamboa Street
corner Salcedo Street, Legaspi Village, Makati City
Tel. No. (+63 2) 985 4322
email: claude.requino@cgrlaw.tk

            info@cgrlaw.tk

website: http://www.cgrlaw.tk

This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. You are hereby notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited.

REVISED REGULATIONS ON LEGITIMATE PARTIES/REPRESENTATIVES AUTHORIZED TO APPEAR DURING INTERVIEW ON APPLICATIONS FOR SECTION 9(g) COMMERCIAL VISA

Operations Order No. SBM-2014-020A

REVISED REGULATIONS ON LEGITIMATE PARTIES/REPRESENTATIVES AUTHORIZED TO APPEAR DURING INTERVIEW ON APPLICATIONS FOR SECTION 9(g) COMMERCIAL VISA

To institutionalize, standardize and identify who are authorized to appear during the hearing/interview conducted by Hearing Officers on application for Section 9(g) Commercial Visa, the following are hereby ordered:

Section 1. -Legitimate Parties/Representatives.- The legitimate persons/representatives are limited to the following:

A. For the Petitioner:
1. Corporation/Partnership - Executive officers as indicated in the Articles of Incorporation/Partnership or latest General Information Sheet (GIS);
2. Single Proprietorship - Registered owner as indicated in the valid Certificate of Business Registration issued by the Department of Trade and Industry (DTI). 

B. For the Applicant:
1. The applicant himself/herself; no representative shall be allowed.

Section 2. Other Officers. - Officers of the petitioners other than those identified in Section 1(A)(1) may represent the said petitioner provided they are authorized by such executive officers through a Special Power of Attorney.

Section 3. Legal Counsels. - Legal Counsel/s of petitioner corporation, partnership or single proprietorship may represent and appear in behalf of said petitioners, its executive officers or registered owner provided they are authorized through a Special Power of Attorney issued by the officer who signed the Consolidated General Application Form (CGAF), Board of Directors' Resolution or Corporate Secretary's Certificate, as the case may be.

Section 4. Travel Agents and Liaison Officers. - Travel Agents and Liaison Officers are not authorized to represent and appear in behalf of the petitioner notwithstanding the issuance of a Special Power of Attorney in their favour.

Section 5. Non-Compliance. – Non-compliance with the Order shall result in the dismissal of the visa application without prejudice to its re-filing.

Section 6. Repealing Clause. – All previous issuances inconsistent herewith are hereby repealed and/or modified accordingly.

Section 7. Effectivity.- This Order shall take effect immediately upon approval.

CGRLAW & Associates

5F First Global Building, 122 Gamboa Street

corner Salcedo Street, Legaspi Village, Makati City
Tel. No. (+63 2) 985 4322
email: claude.requino@cgrlaw.tk
info@cgrlaw.tk
website: http://www.cgrlaw.tk

Need to Know in Anti-Drunk and Drugged Driving Act (RA 10586 s.2014)

The Implementing Rules and Regulations of the Anti-Drunk and Drugged Driving Act (Republic Act No. 10586) has been approved. The law and regulations aim to protect the motoring public and ensure the safety of pedestrians. Here's what you need to know:

Being flagged down

A deputized law enforcement officer (LEO) cannot simply flag down any motorized vehicle and subject the driver to a sobriety test. An officer can only proceed with screening a driver when there is reasonable ground (see: probable cause definition in IRR) to believe that the driver is under the influence of alcohol or drugs, i.e., after witnessing a traffic offense.

How the driver is tested

Field Sobriety Test

Eye test: You must follow with your eyes an object that the officer moves horizontally, a foot away from the your face.

Walk-and-turn test: You must walk nine steps forward in a straight line, turn, and then walk back the same distance.

One-leg stand: You must be able to stand on one leg and raise the other at least 6 inches from the ground and hold that position for thirty seconds.


Alcohol Breath Analyzer (ABA) Test:

If you do not pass the field sobriety test, you will be asked to take the ABA, or breathalizer, test to analyze your blood alcohol level. To pass this test, the driver has to have a blood alcohol concentration level below 0.05%. Drivers of public utility vehicles, trucks, buses, and motorcycles, however have to have a blood alcohol level of 0.0%

Drug Test

If there is reasonable grounds to believe that the driver is under the influence of drugs, the law enforcement officer will bring the driver to the nearest police station, where he will be tested for drugs.

Conditions

If you pass the field sobriety test or the breathalizer test, then you will only be sanctioned or penalized for the traffic offense for which you were pulled over, and thus not subject to penalties of Anti-Drunk and Drugged Driving Act.

If you fail any of the field sobriety test, only then will you be subjected to a breathalizer test.

If you fail the breathalizer test, you will you be arrested; in addition to this, your vehicle will be impounded.

If you refuse to take the test then the LEO shall confiscate and revoke your driver's license, in addition to the other traffic penalties

Those who have passed either the field sobriety test or the ABA test are not obligated to take a drug screening test after the fact.

Confiscated licenses shall only be released after the final disposition or lawful order of the courts.

Penalties

If you violate RA 10586, the penalties range from a minimum of 3 months to a maximum of 20 years imprisonment. The fine ranges from P20,000 to P500,000.

If you own a non-professional license then there is a 12-month suspension on the first offense and a permanent revocation for the second.

If you own a professional license then there is only permanent revocation for a single offense.

www.gov.ph


CGRLAW & Associates

5F First Global Building, 122 Gamboa Street?corner Salcedo Street, Legaspi Village, Makati City?Tel. No. (+63 2) 985 4322?email: claude.requino@cgrlaw.tk
info@cgrlaw.tk
website: http://www.cgrlaw.tk

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A CERTIFICATE OF TITLE TAINTED WITH FRAUD AND MISREPRESENTATION CAN BE A SOURCE OF A VALID TITLE

John Campos falsified the signature of the owner of a parcel of land in a Deed of Sale and was able to transfer the Certificate of Tile to his name. He thereafter sold the property to Spouses Decena, who was purchaser in good faith.

Is the transfer from the real owner of the property to John Campos Valid?

No, it is not valid since it is fraudulent. The Certificate of Title is defective and VOID. It can be cancelled and repudiated anytime.

Is the transfer from John Campos to Spouses Decena Valid?

Yes, it is valid and the Certificate of Title issued to spouses Decena become infallible. Considering that the Spouses Decena are purchaser in good faith, they validly acquire right over the property. 

x--------------------------x

            It is true, a falsified Land Title can be a source of a valid land title. This may occur when the falsified or fraudulent land title is transferred to an innocent buyer in good faith. The buyer must have not known, or could have not known that the property he is buying has a fraudulent Certificate of Title. This is based on the principle that public confidence in the Certificate of Title cannot be impaired.

            "Where innocent third persons, relying on the correctness of the certificate of title thus issued, acquired rights over the property the court cannot disregards such rights and order the total cancellation would be to impair public confidence in the certificate of title, for everyone dealing with property registered under the Torrens System would have to inquire in every instance whether the title has been regularly or irregularly issued. This is contrary to the evident purpose of the law. Every person dealing with registered land may safely rely on the correctness of the certificate of title issued therefor and the law will in no way oblige him to go beyond the certificate to determine the condition of the property."

            It is a familiar doctrine that a forged or fraudulent document may become the root of a valid title, if the property has already been transferred from the name of the owner to that of the forger. This doctrine serve to emphasize that a person who deals with registered property in good faith will acquire good title from a forger and be absolutely protected by a Torrens title. In the final analysis, the resolution of this case depends on whether the petitioners are purchasers in good faith.

What is a purchaser in good faith?

A purchaser in good faith is one who buys property of another without notice that some other person has a right to, or interest in, such property and pays full and fair price for the same at the time of such purchase or before he has notice of the claim or interest of some other person in the property.

Is the principle that a person dealing on a registered land need not go beyond its certificate of title absolute?

            No. The exception to rule is where there are circumstances which would put a party on guard and prompt him to investigate or inspect the property being sold to him, such as the presence of occupants/ tenants thereon, it is of course expected from the purchaser of a valued piece of land to inquire first into the status or nature of possession of the occupants.

What is the remedy of the Real Owner?

            The real owner may file a complaint for the Reconveyance of Certificate of Title fraudulently issued. An annotation may be recorded in the title while the case is pending in court. Nevertheless, if the Buyer is a purchaser in good faith, the real owner may not be able to cancel the title.

            In this instance, the proper remedy would be to file a CRIMINAL CASE FOR FALSIFICATION OF PRIVATE DOCUMENT. Since it is clear that the transfer was fraudulent, the Deed of Sale showing that the forger is the real owner when in fact he is not, a falsification would be a proper action. Falsification has a penalty of imprisonment and, when properly alleged, damages.

(G.R. No. 164801)

CGRLAW & Associates

5F First Global Building, 122 Gamboa Street
corner Salcedo Street, Legaspi Village, Makati City
Tel. No. (+63 2) 985 4322
email: claude.requino@cgrlaw.tk

            info@cgrlaw.tk

website: http://www.cgrlaw.tk

This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. You are hereby notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited.

May a Foreigner be elected as President in a Corporation?

May a Foreigner be elected as President in a Corporation?

The answer would depend on what business the corporation is engaged. If the corporation is engaged in an activity where foreign ownership is restricted under Philippine laws, a foreigner cannot be a President of the corporation.

The Sec. 2-A of Commonwealth Act No. 108, as amended, bans foreigners from being elected or appointed to management positions as president, vice-president, treasurer, secretary, etc. in business activities where there is a constitutional or statutory provision imposing a specific nationality requirement as a requisite for exercise or enjoyment of a right, franchise or privilege. (SEC Opinion No 11-37)

In the opinion of the Department of Justice it states: A reading of Section 2-A readily reveals the legislative intent to complement our nationalization laws by closing any avenue whereby aliens may defeat their purpose (King v. Hernaez, 4SCRA 792). It penalizes the employment of aliens in any position pertaining to management, operation, administration and control, whether as an officer, employee, or labor therein, which means that the employment of a person who is not a Filipino citizen even in a minor or clerical or non-control position is prohibited.

In arriving at this conclusion, I am guided by the underlying intent behind the nationalization of employment provided for in Anti-Dummy Law, which is to eradicate the shackles of foreign economic control and domination in the country (Universal Corn Products, Inc. v. Rice and Corn Board, 20 SCRA 1048)

Therefore, when this circumstance arises, it is advised to check the Negative List to see if the business of the corporation is included in the restricted business, otherwise,  there is no prohibition for an alien to be President.

CGRLAW & Associates
5F First Global Building, 122 Gamboa Street
corner Salcedo Street, Legaspi Village, Makati City
Tel. No. (+63 2) 985 4322/  (+63 2) 889 5210
Mobile: +63 918 948 6092
email:atty.claudio.g.requino@live.com.ph

   claude.requino@cgrlaw.tk

           info@cgrlaw.tk

website: http://www.cgrlaw.tk

This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. You are hereby notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited.

FOREIGN CORPORATION INVESTING IN AN UNINCORPORATED CONSORTIUM NEEDS A LICENSE TO DO BUSINESS IN THE PHILIPPINES

A Foreign Corporation that intends to invest in an unincorporated consortium in the Philippines must have a license to do transact even if it does not hold a controlling interest in the consortium and not the operator of the said consortium.

This is because an unincorporated consortium is considered as a partnership. Hence, it has to comply with the Foreign Investment Act of 1991 and laws on partnership. The answer would be otherwise, if the investment would be in a domestic corporation.

The exception in the Foreign Investment Act, which would not require acquiring license to transact business are as follows:

1.     Mere investment as a shareholder by a foreign entity in domestic corporation duly registered to do business.

2.     Having nominee director to represent its interest in such corporation.

Clearly, the exception pertains to domestic corporations and not to a partnership. Considering that the exemption from the doing business rule pertains only to investment in a corporation, investment in any other business organization, firm or entity (e.g. partnership) would not automatically constitute an exemption. In this connection, participating in the management, supervision or control of any domestic business, firm, entity or corporation in the Philippines is considered doing business. Consequently, following the strict interpretation rule, the only automatically exempt management, supervision or control is that of a corporation (i.e. having nominee director or office to represent its interest in such corporation) and not of any other entity, such as partnership. (SEC Opinion 14-01)

CGRLAW & Associates
5F First Global Building, 122 Gamboa Street
corner Salcedo Street, Legaspi Village, Makati City
Tel. No. (+63 2) 985 4322/  (+63 2) 889 5210
Mobile: +63 918 948 6092
email:atty.claudio.g.requino@live.com.ph

   claude.requino@cgrlaw.tk

           info@cgrlaw.tk

website: http://www.cgrlaw.tk

This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. You are hereby notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited.

DOJ APPROVES VISITOR’S VISA PRIVILEGES

DOJ APPROVES VISITOR'S VISA PRIVILEGES

Bureau of Immigration Commissioner (BI) Siegfred B. Mison revealed yesterday that Justice Secretary Leila De Lima has recently approved a circular on the new policies and guidelines of temporary visitor's visa (TVV) privileges to thousands of foreigners.

Under the new memorandum, Mison said foreigners may extend their authorized stay for a total of not more than 24 months for visa-required and 36 months for non-visa required nationals.

The said extension period shall be counted from the date of applicant's latest recorded arrival, according to the memorandum.

However, foreigners who are in the derogatory list are still authorized to extend their stay as temporary visitors provided that their inclusion on the said list is not based on the ground of overstaying in the country.

Last year, the BI had announced that it was extending the visa-free privileges of foreign visitors to spur tourist arrival in the country, as it aims to attract at 10 million foreign tourists by 2016.
CGRLAW & Associates
5F First Global Building, 122 Gamboa Street
corner Salcedo Street, Legaspi Village, Makati City
Tel. No. (+63 2) 985 4322/  (+63 2) 889 5210
Mobile: +63 918 948 6092
email:atty.claudio.g.requino@live.com.ph

   claude.requino@cgrlaw.tk

           info@cgrlaw.tk

website: http://www.cgrlaw.tk

This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. You are hereby notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited.

Chinese New Year, a special non-working day, must be observed with deference to proper pay rules for employees--Baldoz

Chinese New Year, a special non-working day, must be observed with deference to proper pay rules for employees--Baldoz

Labor and Employment Secretary Rosalinda Dimapilis-Baldoz yesterday urged all employers in the country's private sector to promote workers' welfare and protection by observing the proper pay rules and other core labor standards during the Chinese New Year on 31 January 2014 which is a special (non-working) day in the Philippines.

President Benigno S. Aquino III declared the day a special (non-working) under Proclamation No. 655, Series of 2013, Declaring the Regular Holidays, Special (Non-Working) Days, and Special Holiday (For All Schools) For the Year 2014, which he issued on 25 September 2013.

"On 31 January 2014, Chinese nationals all over the world will celebrate Spring Festival, popularly known as the Chinese New Year, which is one of the most revered and festive events celebrated not only in China, but also in the Philippines, by both Chinese-Filipinos and ordinary Filipinos. The joint celebration is a manifestation of our solidarity with Chinese-Filipinos who have been part of our country in many respects," said Baldoz.

Thus, the labor and employment chief reiterated that proper observance of the pay rules on this day is a decent work standard that encourages productive and efficient workers, adding that voluntary compliance with labor laws, including correct wage payment during holidays, promotes workplace excellence and redounds to the competitiveness of business and the country's industries.

Pursuant to Labor Advisory No. 14, Series of 2013, which Baldoz issued on 20 December 2013, the proper pay rules to be observed for the special non-working holiday on 31 January 2014 are as follows:

(a) If the employee did not work, the "no-work, no-pay" principle shall apply unless there is a favorable company policy, practice, or collective bargaining agreement (CBA) granting payment on a special day;
(b) If the employee reports for work, he shall be paid an additional 30 percent of his daily rate on the first eight hours of work. The standard computation for this is as follows: [(Daily rate x 130 percent) + COLA)];
(c) For work done in excess of eight hours (overtime work), he shall be paid an additional 30 percent of his hourly rate on said day. (Hourly rate of the basic daily wage x 130 percent x 130 percent x number of hours worked);
(d) For work done during a special day that also falls on an employee's rest day, he be paid an additional 50 percent of his daily rate on the first eight hours of work. [(Daily rate x 150 percent) + COLA]; and
(e) For work done in excess of eight hours (overtime work) during a special day that also falls on an employee's rest day, he shall be paid an additional 30 percent of his hourly rate on said day. (Hourly rate of the basic daily wage x 150 percent x 130 percent x number of hours worked).

Any question on this release, please call DOLE Hotline 527-8000, the Bureau of Working Conditions (BWC) at DOLE trunkline 527-3000 locals 301 or 307, or the DOLE Regional Office nearest your area (for DOLE-NCR tel. no. 400-60-11).

Date Posted: January 9th, 2014 06:28 AM at http://www.dole.gov.ph/news/view/2343

CGRLAW & Associates

5F First Global Building, 122 Gamboa Street
corner Salcedo Street, Legaspi Village, Makati City
Tel. No. (+63 2) 985 4322/  (+63 2) 889 5210
Mobile: +63 918 948 6092
email:atty.claudio.g.requino@live.com.ph

   claude.requino@cgrlaw.tk

           info@cgrlaw.tk

website: http://www.cgrlaw.tk

This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. You are hereby notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited.