The Assignment

We need the groups to do two things: (a) find out exactly what documents we need to support the
allegations, then (b) make those documents.
These are our allegations. If its not clear what the story is, please see the counter-affidavit and
plot weve prepared. More than one proof per allegation is fine.
1. Irreversible economic losses, forcing Hacienda La Consulacion, Inc. (HLCI) to
temporarily close from 3 August 2011 to 2 January 2012.
Suggestions: Financial statements to the effect that the company has not been liquid in the
first three quarters of 2011; that there was sudden decrease in cash + increase in accounts
receivable and bad debts.
2. Resumption of business on 3 January 2012
3. Receipt of demand letter on 25 September 2013
4. Efforts to clarify with Joselito Mendoza why HCLI needed to pay when it was shut down,
dated 25-27 September 2013
5. Payment on 28 September 2013 of SSS contribution + Proof of sending copy to Mendoza
6. Communication to SSS (not through Mendoza) that we paid on 28 September and that
HCLI had shut down August 2011 to January 2012, dated 30 September 2013
7. SSS acknowledges that HCLI did not need to pay October to December 2011, so it
promises to withdraw its complaint
8. Mendozas longstanding beef with HCLI
9. Mendoza knowing about/being in possession of documents establishing HCLIs
shutdown from August 2011-January 2012, and hiding that information
10. Mendoza evading our inquiries on 25-27 September 2013
11. Mendoza knowing about/being in possession of documents establishing the fact of
HCLIs payment on 28 September 2013

Five groups, so each group take two allegations each. Whatevers left behind is for my group.
Please state your choices in the comments area.
But Ocampo-Magugat group, please take three allegations, as youve been quiet so far.