Republic of the Philippines

[Region]
[Court]
Branch ___
City

JOHN DOE, CIVIL CASE No. 000001

Plaintiff, For: SUM OF MONEY

vs.

U.S.A HOLDINGS, INC.,

Defendant,
x--------------------------------------------x

MOTION FOR PRODUCTION OF

DOCUMENTS OR THINGS
WITH NOTICE FOR HEARING

COMES NOW the plaintiff, through counsel and to this Honorable

Court, most respectfully moves for an order requiring defendant U.S.A
Holdings, Inc.:

1. To produce and permit plaintiff to inspect and to copy each of the

following documents:

a. Independently Audited Financial Statements, and the

corresponding receipts, sales, purchase invoices and expenses
receipts, and other similar documents which were made basis
thereof, covering the year 2015, 2016 and 2107;

b. General Information Sheet of the U.S.A Holdings Inc., covering

the year 2015, 2016 and 2017;

c. Bank Account Statements from each Bank you have an account

with covering the 2015, 2016 and 2017;

d. Sales Invoices covering the year 2015, 2016 and 2017;

e. Purchase Invoices and Expenses Receipts covering the period

from 2015 to 2017; and

f. Payroll Records covering the year 2015, 2016 and 2017.

2. To permit plaintiff to enter Warehouse No. 10, located at City,

Philippines and to inspect and photograph the following:
 a. The Stock Room 1, which is used for storing all the linens, pillow
case, beed sheets, curtains and other similar or related items;

b. The Stock Room 2, used to store new, refurbished or repaired

doors, door knob, windows and other similar or related items; and

c. The Stock Room 3, used to store new, refurbished or repaired

electrical supplies, including light bulbs, lamps and other similar
or related items, or mechanical supplies, including carts, baggage
carries and other similar or related items.

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.

___ City, Philippines. February 5, 2018.

JOHN DOE
Plaintiff

NOTICE OF HEARING

THE BRANCH CLERK OF COURT

[Court]- Branch __
___ City

Greetings!

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, 16 February 2018 at 8:30 in the
morning.

Copy furnished by personal service:

ATTY. DEXTER
Counsel for the Defendant
[Office Address]

Please take notice that counsel has requested to be heard on Friday, 16

February 2018 at 8:30 in the morning.
 PROOF OF SERVICE

I, ANDRÉ MANGCHU, messenger for Atty. Cyrus D. Virus, hereby

certify that, I personally delivered Plaintiff’s MOTION FOR PRODUCTION
OF DOCUMENTS OR THINGS WITH NOTICE FOR HEARING dated 5
February to Atty. Dexter, with address at _________________________ City,
Philippines. This Motion was received by the counsel himself.

SUBSCRIBED AND SWORN to before me this 6nd day of February

2018 at ____ City affiant exhibiting to me his ID no. _____ issued on February
20, 2012 at ___ City.