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Plaintiff,: Complaint
Plaintiff,: Complaint
X, Inc.
Plaintiff,
Y and Z
Defendants.
x---------------------------x
COMPLAINT
1) Plaintiff is a corporation duly organized and existing under the laws of the
Philippines, with principal office at Suite 501 and 502, Metropolitan Tower, 1746
Mabini Street, Malate, Manila; it is represented herein by its president, X.
Defendants Y and Z are both of legal age and with residences at Forbes Park,
Makati City, Metro Manila, Philippines and Unit 1, The Fort Residences,
Bonifacio Global City, Metro Manila, Philippines, respectively, where they may be
served with summons and other legal processes.
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5) Confronted with the conflicting claims of ownership of said shares of
stock, plaintiff held in abeyance action of their respective claims and demanded of
defendants Y and Z to interplead and litigate their respective claims, but they
refused and continue to so refuse.
PRAYER
I, X, of legal age, Filipino and holding office at Suite 501 and 502,
Metropolitan Tower, 1746 Mabini Street, Malate, Manila, declares under oath that:
2. The facts stated in the above complaint are true and correct to the best of
my knowledge and authentic records;
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3. I have not commenced any action or filed any claim involving the same
issues in any court, tribunal or quasi-judicial agency and, to the best of my
knowledge, no such other action or claim is pending in them; and
4. If I should learn that the same or similar action or claim has been filed or
is pending after its filing, I shall report that fact within five (5) days from notice to
the court or where the complaint or initiatory pleading has been filed.
(Sgd.) X
NOTARY PUBLIC
Doc. No. _______; Commission Serial No. _______
Page No. _______; Until December 31, __________
Roll of Attorney _____________
Book No. _______;
IBP No. _______/Date/Place of Issue
Series of _______. PTR No. _______/Date/Place of Issue