Republic of the Philippines

____________ Judicial Region

________________ TRIAL COURT

Branch _____, _____________, _____________

PETITION FOR APPLICATION FOR REPLEVIN

Plaintiff by counsel and by this Honorable court respectfully alleges that:

1. Plaintiff has filed an action for Replevin and damages in the above captioned case against the defendant, in connection of the refusal of the defendant to return the personal property of the plaintiff despite repeated demands.

2. Plaintiff have been deprived of the use of said personal property and income as a result of failure to return property.

3. Plaintiff is ready to and willing to post a bond as the court may fix, executed to the defendant in case judgment be not in favor of the plaintiff, and for the payment of such sum as the defendant may recover in the action.

WHEREFORE, plaintiff respectfully prays that said personal property be returned by the defendant with such other costs by which the court may deem just under law and equity.

Manila, Philippines. March 5, 2012.

(Sgd.) _____________________________

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