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
-versus-
PRETTY CORPORATION,
Defendant.
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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

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limitation, correspondence, memoranda, notes diaries, statistics,
letters, telegrams, minutes, contracts, reports, studies, checks,
statements, receipts, returns, summaries, pamphlets, books, inter-
office and intra-office communications, notations of any sort
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

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ATTY. GEORGE DIMAGIBA
Branch Clerk of Court
Branch 800, Regional Trial Court
Hall of Justice, Carig, Tuguegarao 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, 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.