Republic of the Philippines

____________ Judicial Region

________________ TRIAL COURT

Branch _____, _____________, _____________

COMPLAINT

PLAINTIFF, by counsel, respectfully states that:

1. Plaintiff and defendants are all of legal age; plaintiff resides at ________________ while defendants reside at _______________ and _______________, respectively, where they may be served with pertinent notices.

2. On 1 June 2007, plaintiff found a Gold Rolex Oyster watch, without knowing who its true owner is. The watch is now in plaintiff’s possession. On or about 5 June 1999, defendants made similar representations to plaintiff as to ownership of the watch.

3. Plaintiff, who claims no interest in the watch, cannot determine the conflicting claims of defendants and thus seeks to compel defendants to interplead and litigate their several claims between themselves.

WHEREFORE, it is respectfully prayed that this Honorable Court issue an order directing defendants to interplead with one another to determine their respective rights and claims and to allow plaintiff to recover his expenses for safekeeping and the costs of this suit, as first lien upon the subject matter of this action.

Quezon City for Makati; 13 April 2007.

(Sgd.) _____________________________

Counsel for Plaintiff