Form of a Motion for Production

Under Rule 27

(Caption and Title)

MOTION FOR PRODUCTION
NOW COME the petitioners in the above-entitled case and pursuant to Sec. 1 of Rule 27 of the
Revised Rules of Court, respectfully move that the respondents Bangko Sentral ng Pilipinas and the Monetary
Board be ordered to produce for inspection and copying by the petitioners, or their duly authorized
representatives, the following documents:

1. The Minutes of the Monetary Board meeting purportedly held on August 24, 2007, where the
examination findings conducted on December 31, 2006 on Sandigan Savings and Loan Bank was
presented.
2. The report of Ms. Leilani M. Canullas, Director, Supervision and Examination Department IV
dated August 2, 2007.
3. Monetary Board Resolution No. 946 dated August 24, 2007.
4. The different rehabilitation plans submitted to the BSP by Sandigan Savings and Loan Bank.
5. The dacion en pago agreement executed by Sandigan Savings and Loan Bank in favor of the
Bangko Sentral ng Pilipinas sometime in 1998 to liquidate an emergency loan in the amount of
P97, 741.
6. The different requests submitted by Sandigan Savings and Loan Bank to the BSP prior to August
24, 2007.
7. Replies, if any, sent by BSP to the Sandigan Savings and Loan Bank to its repeated requests for
emergency loans.
8. Copy of the memorandum of agreement dated July 5, 2006 executed by Sandigan Savings and
Loan Bank with Makati Finance Corporation together with the corporate profile and the bio-data
of the directors of Makati Finance Corporation.
9. Letter of Director Caballa of the BSP to a certain Ms. Orbeta of PDIC dated June 14, 2006.
10. The reply of PDIC to the letter of Director Caballa.
11. The letters of F.B. Bugayong and Partners to BSP inquiring on the status of the requests and
rehabilitation plans of Sandigan Savings and Loan Bank.

All the afore-enumerated documents constitute or contained evidence material to the issues raised in
the instant case and are not privileged in character.

PRAYER
WHEREFORE, it is respectfully prayed that this Honorable Court order the respondents Bangko
Sentral ng Pilipinas and Monetary Board to produce before this Honorable Court on such date and hour as it
may fix, and under such terms and conditions as it may prescribe, all the afore-enumerated documents for the
purpose of having the petitioners inspect, copy or take photographs thereof.

(Place, date, Signature and Notice of Hearing)

Form of a Notice to Produce
Under Sec. 6, Rule 130

(Caption and Title)

The Secretary
Monetary Board
Bangko Sentral ng Pilipinas
Roxas Blvd., Manila

G R E E T I N G S:
You are hereby requested, pursuant to the provisions of Sec. 6 of Rule 130 of the Rules of Court to
produce the originals of the following documents at the hearing of the above-entitled case set on March 3,
2011, at 8:30 o’clock in the morning:

(List and Description of Documents)

The originals of the aforelisted documents are in your possession and are not privileged in character.
Your failure to produce the aforesaid originals before the court on the date and hour afore-indicated
shall compel the undersigned to present secondary evidence of the aforelisted documents.

(Place, date and signature)

Form of a Motion for Physical Examination

(Caption and Title)

MOTION FOR PHYSICAL EXAMINATION

NOW COMES the plaintiff in the above-entitled case and by its undersigned counsel respectfully
moves this Honorable Court to order the defendant to submit to a physical examination by a physician, upon
the following considarations:
1. The instant case involves a claim by the plaintiff that he is the son of the defendant, which claim,
the latter has denied.
2. For the purpose of establishing the truth or the falsity of the aforesaid claim, it is necessary to
have the defendant subjected to physical examination under the Rule on DNA Evidence
specifically Sec. 3 (f) thereof.

PRAYER
WHEREFORE, it is respectfully prayed that this Honorable Court order the defendant to submit to
a physical examination under Sec. 3 (f) of the Rule in DNA Evidence by a physician to be appointed by this
Honorable Court and on such date and hour as this Honorable Court may fix.

The plaintiff also prays for such other measures of relief as this Honorable Court may deem just and
proper in the premises.
(Date, Place, Signature and Notice of Hearing)