REPUBLIC OF THE PHILIPPINES METROPOLITAN TRIAL COURT Quezon city Branch 174 JERRY MELIN, Plaintiff,

-versus-

SPECIAL CIVIL CASE No. 30921 FOR: INTERPLEADER

BETH ACOSTA-LOT and REGINA NATUTO Defendant.

x----------------------------------------------------------------------------------------------------------------------------x COMPLAINT

COMES NOW the plaintiff by the undersigned attorney, and unto this Honorable Court, respectfully avers: 1. That the plaintiff is all of legal age, and residents of #7 Houston St., Racquet subdivision, Quezon city, Philippines; 2. That on or about 13, January, 2014, the plaintiff found certain Lou Boatin handbag worth about nine hundred and twenty-five thousand pesos (Php 925,000.00) in the vacant lot next to the plaintiffs house in the aforementioned address herein; 3. That the said handbag is now in the possession of the plaintiff; 4. That on or about 20, January, 2014, at about eight oclock in the morning, Beth AcostaLot, a neighbor, approached the plaintiff and claimed that she had owned the said handbag in question; 5. That on the same day, but at about two oclock in the afternoon, Regina Natuto also approached the plaintiff and claimed that the same handbag in question was hers; 6. That the plaintiff did not give the handbag to any of them as they did not provide any proper proof that it was theirs, and that the plaintiff is still in the possession of said handbag; 7. That both plaintiffs had contacted Police authorities to take the said handbag away without any search and seizure order presented to me; 8. That the plaintiff brings this action against the conflicting claimants to compel them to interplead and litigate their several claims among themselves. WHEREFORE, it is respectfully prayed of this Honorable Court: a. to issue an order summoning the defendants to interplead with one another so as to determine their respective rights and claims; b. to issue a Temporary Restraining order against the seizure of the said handbag by the Police authorities;

c. to allow plaintiff to recover his expenses for safekeeping, and the costs of this suit, to be charged as first lien upon the subject matter of this action. 17, February, 2014

Atty. Lawrence Emmanuel Solis Unit A-1, Graham Bldg. Makati City, Philippines