REPUBLIC OF THE PHILIPPINES

Department of Justice
National Prosecution Service
OFFICE OF THE CITY PROSECUTOR
COTABATO CITY

WARDELL STEPHEN CURRY II,

Complainant,

- versus - IS. No. 11E-03792

For: Reckless Imprudence
Resulting in Homicide (Art.
365 of the Revised Penal
Code)
LEBRON R. JAMES,
Respondents.

SUPPLEMENTAL COMPLAINT-AFFIDAVIT

I, WARDELL STEPHEN CURRY II, of legal age, Filipino and

may be served with summons and other notices through my counsel at
Nikola Jokic & Bogdanovic Law Firm, 2nd Fir. OMP Bldg., De Mazenod
St., Cotabato City, after having been sworn in accordance with law,
hereby depose and state that:

1. I am the husband of Ayesha Curry. I am a Full NBA player of

the Golden State Warriors. My wife Ayesha was killed when the taxi
she was on board was rammed from behind by a bus on November 13,
2026 along Sinsuat Avenue. A copy of our Marriage Certificate is
attached as Annex "A" and made an integral part hereof.

2. I am executing this Supplemental Complaint-Affidavit to charge

Daniel O. Espinosa, the driver of the bus, for the QUALIFIED
OFFENSE OF RECKLESS IMPRUDENCE RESULTING IN
HOMICIDE, defined and punished under Article 365 of the Revised
Penal Code for the death of AYESHA. The offense was committed
under the circumstances narrated below.
3. This Complaint-Affldavit is supplementary to the complaint
that has already been filed by the police authorities or the other
offended party before this Honorable Office.
 4. Respondent Daniel O. Espinosa is employed as a bus driver
of Universal Guiding Star Bus Line Corporation. The latter is an entity
engaged in the business of public transportation and also owns the
bus driven by respondent Espinosa which caused the death of my
wife.

5. On May 13, 2011, at approximately 6:00 p.m., my wife-)

Lourdes Simbulan was seated on the back passenger seat of a taxi
bearing the name Abu Abbey taxi and with plate number TXH 532,
which was traveling along Commcnwealth Avenue, heading in the
direction of the UP-Ayala Technohub, where she had a dinner
appointment with her friends. I Vias suppose to fetch her there at
around 9:00 pm that evening.

6. While the Abu Abbey taki was in the area of the UP-Ayala

Technohub, a passenger bus of the Universal Guiding Star Bus Line

Corporation with plate number UVC 343, being driven by respondent
Daniel Espinosa, with reckless imprudence, rammed into its rear end.
I have been informed that photographs of the damage of the taxi were
taken by the police investigators to which I have no access to. I
reserve the right to present those photographs and others that I may
acquire at the proper time.

7. As a result of the collision by the bus on the back of the Abu

Abbey taxi, its entire rear trunk was crushed, if not pushed into the
rear passenger compartment where CHIT was seated. As a result,
CHIT who was seated at the rear passenger seat was pinned there
and absorbed the tremendous impact of the collision thereby. causing
serious injuries that resulted in her death. She was brought to the
Matvar Hospital along Commonwealth Avenue where she was
pronounced dead on her arrival. A copy of my wife's Death
Certificate is attached as Annex and made an integral part hereof.

8. After the bus rammed into the taxi, respondent Daniel Espinosa
fled the scene without rendering any assistance to my injured wife. A
copy of the police Spot Report Dated 13 May2011 is attached as
Annex "C" and made an integral part hereof.

9. At the time of CHIT's death she was a full-time professor

with the College of Mass Communications at the University of the
Philippines and had just been given tenure. She had been previously a
Malacanang and Congressional reporter for the Pahayagang Malaya,
the Philippine Daily Inquirer, and had capped her career as Managing
Editor and later Editor in Chief of the national daily, The
Manila Times, and as Editor in Chief of the Pinoy Times. Attached as
Annex I'D" is a copy of my wife's Notification of Approval of
Employment dated 16 June 2009 which is made an integral part
hereof. Her new appointment as Assistant Professor Il has just been
approved. I reserve the right to present a more recent employment
record showing her present salary and, income from other sources in
her professiòn as a well-known journalist with a total estimated basic
income of at least P400,000. per annum.

10. She was one of the founders of and current corporate

secretary of VERA FILES, a group of investigative journalists, and was
completing two book projects for Anvil Publishing. She is also a multi-
awarded journalist having received in 2006 the Developing Asia
Journalism Awards, given by the Asian Development Bank. CHIT
bested almost 250 other Asian journalists from 60 Asian countries
whose works were evaluated for their relevance to Asian development
issues. CHIT also received the the Catholic Mass Media Awards for
Journalism in 2003.

11. Due to my wife's untimely death, I incurred funeral

expenses in the approximate amount of P350,000. pesos, which was
spent for food and other related expenses during the six day wake
including the 9th day. The said amount includes P75,000, for the
columbarium, and Catholic masses. I reserve the opportunity to
present the receipts for such expenses at the proper time. The other
funeral expenses were shouldered by Universal Guiding Star Bus Line
Corporation.

12. CHIT and I were supposed to celebrate our 30th wedding

anniversary this year. Not having ben blessed with children, CHIT and
I for the past 30 years lived for each other as an integral and
inseparable whole. The absence of r)ne is unthinkable and may be
unbearable. Her sudden, unexpected 3nd violent death has therefore
deeply shocked and traumatized me, and caused me great emotional
distress.

13. After her death, and since CHIT and I lived alone, I had,
and continue to have trouble steeping. I also experienced, and continue
to experience, serious anxiety and great mental anguish she being my
sole companion and soulmate. Because of this I have been advised to
seek professional help for CHIT's sudden, unexpected and violent
demise.

14. Given the extraordinary circumstances of CHIT's violent and

sudden death, caused by the reckless imprudence of Daniel O.
Espinoso, I intend to claim in the same criminal case any and all
possible civil liabilities as provided for in Arts. 100, 102 and 103 of the
Revised Penal Code arising from the his criminal act, including but
not limited to, actual, moral, and exemplary damages, the exact
amounts of which I will prove during trial. I also intend to claim
attorney's fees.

15. Accordingly, I am executing this Supplemental Complaint

Affidavit for the purpose of attesting to the truth of the foregoing
statements' and to charge respondent Daniel Espinosa with Reckless
Imprudence Resulting in Homicide, qualified by his act of fleeing the
scene of his reckless act, thus failing to lend on the Spot such help as
may be in his hand to give to the injured parties, as provided for in
Art. 365 of the Revised Penal Code.

IN WITNESS HEREOF, 1 hereunto set my hand this 31 st day of

May 2027 in Cotabato City.

WARDELL STEPHEN CURRY II

Affiant

SUBSCRIBED AND SWORN to before me this 31 st day of May

2027 in Cotabato City.