Interpleader

REPUBLIC OF THE PHILIPPINES NATIONAL CAPITAL JUDICIAL REGION REGIONAL TRIAL COURT BRANCH 39, QUEZON CITY

JUAN DELA CRUZ, Plaintiff, -

VERSUS –

Special Civil Action No. _______ Petition for Interpleader

JUAN TAMAD and JUAN TANGA, Defendant, x--------------x COMPLAINT I, JUAN DELA CRUZ, through the counsel, respectfully states that: 1. Plaintiff and defendant are all of legal age; plaintiff resides at 1234 Hillsborrough St. White Plains Village Quezon City, whereas defendants resides at 5678 Manggahan St. White Plains Village Quezon City and 9012 Ampalaya St. White Plains Quezon City respectively, where they may be served the respective notices; 2. That on January 31st of 2012, plaintiff found a Bag containing Macbook laptop, 1 Hard Drive, a check worth twenty five thousand pesos (pay to cash) and a Blackberry playbook that said properties where in the possession of the plaintiff. 3. On 10th of February 2012, defendants made similar representations to the plaintiff as the rightful owner of the said properties without even showing proof that he own as such. 4. Plaintiff who claims no interest on the said properties cannot determine the conflicting claims of defendants and thus seeks to compel defendants to interplead and litigate their several claims between themselves.

WHEREFORE, I respectfully prayed before this Honorable Court to issue and order directing defendants to interplead with one another and to determine their respective rights and claims and to allow plaintiff to recover his expenses and the costs of this suit as first lien upon the subject of this action Quezon City, 21st of February 2012

(sgd.) Atty. Aron Kerr Menguito Counsel for the Plaintiff Unit 1234 Eastwood City Libis, Quezon City Roll of Attorney No. 1 IBP No. 2 MCLE Compliance

CERTIFICATION AND VERIFICATION OF NON FORUM SHOPPING REPUBLIC OF THE PHILIPPINES CITY OF QUEZON

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S.S.

I, JUAN DELA CRUZ, after having been duly sworn in accordance with the law, deposes and states that: 1. I am the plaintiff in the above titled case; 2. I am of legal age and as of the moment in possession of the said properties mention in the above titled case; 3. I certify that I have not commenced any action or filed any claim involving the same issues before any other court and quasi-judicial agency; 4. To the best of my knowledge there is no such pending action or claim, or in case there arise I will personally report to the Honorable Court the status of the same within 5 days; IN WITNESS WHEREOF, I have signed this instrument on 21 st of February 2012.

(Signed) JUAN DELA CRUZ