Motion For Production Of Documents.docx

Republic of the Philippines REGIONAL TRIAL COURT Second Judicial Region BRANCH 800 Tuguegarao City JDB BANK

Plaintiff, Civil Case No. 1123 For: Collection of Sum of Money

-versusPRETTY CORPORATION, Defendant. x - - - - - - - - - - - - - - - - - - - - - - - - -x MOTION FOR PRODUCTION OF DOCUMENTS COMES NOW, plaintiff, by counsel moves for an order requiring defendant Pretty Corporation through its Treasurer/Chief Financial Officer, Chief Accountant, Comptroller or any such officer, to bring before this Honorable Court for inspection and copying the following documents: 1) The originals, duplicate originals and copies of all documents pertaining to, arising from, in connection with or involving the Back-end Services Agreement of defendant Pretty Corp. And Gada Corp.; 2) The originals, duplicate originals and copies of all books of account, financial statements, receipts, checks, vouchers, invoices, ledgers and other financial/accounting records and documents pertaining to or evidencing financial and money transactions arising from, in connection with or involving the Back-end Services Agreement of defendant Pretty Corp. And Gada Corp.;and 3) The originals, duplicate originals and copies of all documents from whatever source pertaining to the proceeds/payments received by Pretty Corp from Ganda Corp.. 4) Documents, as used in this section, means all writings of any kind, including the originals and all non-identical copies, whether different from the originals by reason of any notation made on such copies or otherwise, including without limitation, correspondence, memoranda, notes diaries, statistics, letters, telegrams, minutes, contracts, reports, studies, checks, statements, receipts, returns, summaries, pamphlets, books, interoffice and intra-office communications, notations of any sort 1

of conversations, telephone calls, meetings or other communications, bulletins, printed matter, computer records, diskettes or print-outs, teletypes, telefax, e-mail, invoices, worksheets, all drafts, alterations, modifications, changes and amendments of any of the foregoing, graphic or oral records or representations of any kind (including, without limitation, photographs, charts, graphs, microfiche, microfilm, videotapes, recordings, motion pictures, CD-ROMs), and any electronic, mechanical or electric records or representations (including, without limitation, tapes, cassettes, discs, recordings and computer or computer-related memories). WHEREFORE, pursuant to Rule 27 of the Rules on Civil Procedure, plaintiff prays that an order be issued directing the defendant Pretty Corporation to bring all the records and documents, not privileged, arising from, in connection with and/or involving the Back-end Services Agreement with Ganda Corporation, particularly to those pertaining to all payments made by Ganda Corp. To Pretty pursuant to said Agreement. Other reliefs, just and equitable, are likewise prayed for. 27 February 2019, Tuguegarao City, Cagayan. DINA NATUTO Counsel for Plaintiff

30 Molave Stree, Capatan Tuguegarao City Roll No. 111787 PTR No. 888 (01/03/2019) IBP O.R.No.777 (01/05/2019) MCLE Compliance No. A-222 (01/06/2019)

NOTICE OF HEARING ATTY. GEORGE DIMAGIBA Branch Clerk of Court Branch 800, Regional Trial Court Hall of Justice, Carig, Tuguegarao City Greetings!

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Please submit the foregoing Motion to the Court for its consideration and approval immediately upon receipt hereof and kindly include the same in the court’s calendar for hearing on Friday, 1 March 2019 at 8:30 in the morning

DINA NATUTO Counsel for Plaintiff

30 Molave Stree, Capatan Tuguegarao City Roll No. 111787 PTR No. 888 (01/03/2019) IBP O.R.No.777 (01/05/2019) MCLE Compliance No. A-222 (01/06/2019) Copy furnished: ATTY. ALIETA JOSE Counsel for the Defendant 17 Pilapil Street, Larion Bajo Tuguegarao City, Cagayan Please take notice that counsel has requested to be heard on Friday, 1 March 2019 at 8:30 in the morning.

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