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Republic of the Philippines
____________ Judicial Region
________________ TRIAL COURT
Branch _____, _____________, _____________
______________________,
Plaintiff,
-versus-
______________________,
Defendant.
x - - - - - - - - - - - - - - - - - - - - - - - - -x
Civil Case No ____________________
FOR: _____________________________
MOTION FOR PRODUCTION OF DOCUMENTS
MOTION FOR PRODUCTION OF DOCUMENTS
PLAINTIFF, by counsel, moves for an order requiring defendant ___________________________:
To produce and permit plaintiff to inspect and to copy each of the following documents: (Here, list the documents and describe each of them)
To produce and permit plaintiff to inspect and to photograph each of the following objects: (Here, list the objects and describe each of them)
To permit plaintiff to enter (here describe property to be entered) and to inspect and photograph (here describe the portion of the real property and the objects to be inspected and photographed)
Defendant has the possession, custody or control of each of the foregoing documents and objects and of the above-mentioned real estate. Each of them constitutes or contains evidence relevant and material to the matter involved in this action.
Manila, 29 November 2013
ATTY. ___________________________________
Counsel for Plaintiff
Notice of Hearing
THE CLERK OF COURT
RTC Branch 113
Pasay City
HON. SOLICITOR GENERAL
134 Amorsolo St., Amorsolo Bldg.,
Legaspi Village, Makati City
OFFICE OF THE CITY PROSECUTOR
Pasay City
ELLEN A. ADARNA
316 Palin St., Block 27 Lot 77
Ai- Ai, General Tinio, GMA, Cavite
Greetings:
Please submit the foregoing motion for the consideration and approval of the Honorable Court immediately upon receipt hereof.
RICA KAYE O. LOMIBAO
Copy furnished:
HON. SOLICITOR GENERAL
134 Amorsolo St., Amorsolo Bldg.,
Legaspi Village, Makati City
OFFICE OF THE CITY PROSECUTOR
Pasay City
ELLEN A. ADARNA
316 Palin St., Block 27 Lot 77
Ai- Ai, General Tinio, GMA, Cavite
Explanation
The foregoing motion is being filed to the Honorable Court, Office of the City Prosecutor and to the other party by personal service with copy therefore furnished to the Office of the Solicitor General by registered mail, due to the distance of the undersigned from the said Honorable Solicitor General, making personal service thereof not practicable.
RICA KAYE O. LOMIBAO
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