sonocs 4 z vt Peer = ta Posted on this receipt for roterence in case of Inquiry Preserve REPUBLIC OF THE PE AES ELEVENTH JUDICIA Postmaster/Teller REGIONAL TRIAL _. -.-- Ye BRANCH 37, GENERAL SANTOS CITY BERNABE NAVIDA, ET AL., Plaintiffs, ~ versus - CIVIL CASE NO. 5617 SHELL OIL COMPANY, ET AL., Defendants. x x MANIFESTATION (RE FILING AND SERVICE OF FORMAL OFFER OF EVIDENCE) Defendants THE DOW CHEMICAL COMPANY (“Dow”) and OCCIDENTAL CHEMICAL CORPORATION (“Occidental”), through counsel, respectfully state: 1. At the 2 June 2022 hearing, the Honorable Court directed defendants Dow/Occidental and Shell Oil Company (“Shell Oil”) to file their respective formal offers of evidence within fifteen (15) days from 2 June 2022, or by 17 June 2022. 2. In-view of Dow/Occidental's very voluminous exhibits (consisting of 2 balikbayan boxes weighing at least twenty (20) kilograms each, or a total of forty (40) kilograms) and the time and cost constraints of photocopying the same, Dow/Occidental respectfully manifest that it will file and serve their Formal Offer of Evidence and exhibits in the following manner: 2.1. The original Formal Offer of Evidence with (a) the originally marked exhibits attached, and (b) scanned copies of the exhibits saved in a flash drive — will be filed by hand with the Honorabie Court on or before 17 June 2022. 2.2. The other parties shall be served with copies of Dow/Occidental’s Formal Offer of Evidence by email, registered mail, and courier. 2.2.1. Due to the number of parties to be served, the hard copies of the exhibits will not be attached to Dow/Occidental's Formal Offer of Evidence. However, a flash drive will be included/provided to the other parties, which will containscanned copies of the exhibits. In addition, a secure link will be provided in the cover email of the electronic service of the Formal Offer of Evidence, where the scanned copies of the exhibits may also be viewed/downloaded.! 2.2.2. Further, the other parties already have copies of the majority of these exhibits, as they were attached to the following previous pleadings/submissions of Dow/Oceidental: * "First Partial Compliance Ad Cautelam (with Order dated 13 November 2013) with Motion for (1) Inventory of Records, (2) Comparison of Records and (3) Extension of Time" dated 16 December 2013; "Second Partial Compliance Ad Cautelam (with Order dated 13 November 2013)" dated 19 December 2013; "Third Partial Compliance Ad Cautelam (with Order dated 13 November 2013) with Motion for Pre-Marking" dated 14 January 2014; "Fourth Partial Compliance Ad Cautelam (with Order dated 13 November 2013) with Motions for Comparison and Pre-Marking" dated 20 January 2014; "Fifth Partial Compliance Ad Cautelam (with Order dated 13 November 2013) with Motion (1) for Pre-Marking and (2) to Take Judicial Notice" dated 6 July 2015:" Sixth Partial Compliance Ad Cautelam (with Order dated 13 November 2013) with Motion for Pre-Marking" dated 6 July 2015; and "Seventh Partial Compliance Ad Cautelam (with Order dated 13 November 2013) with Motion for Pre-Marking" dated 27 July 2015 RESPECTFULLY SUBMITTED. Taguig City for General Santos City, 15 June 2622. "In an Ordes dated 17 Novembes 2020, the Honorable Cour directed the parties to "submit a manifestation oftheir willingness or consent to be served with Cour-issued orders and other documents, us well a pleadings, motions or similar papers by the opposing party/counsel by electronic mcans, subject tothe exceptions under Sections 13/14”. The originally marked exhibits donot fll within the ambit of documenis that must oaly be ies personally or by registered mail under Sections 13 sad 14 of Rule 13 of the Rules of Cows.QUISUMBING TORRES Counsel for Dow/Occidentai 16/F One/NEO Building 26" Street comer 3™ Avenue Crescent Park West, Bonifacio Global City Taguig City, Metro Manila Telephone: +632 8819-4700 Facsimile: +632 8816-0080 juisumbit rres.com wth iSUMBING Rol feys No. 37177 IBP Lifetime No, 03312; 01/05/04; Makati City PTR No. A-5400917; 01/18/22; Taguig City MCLE Compliance No. Vi-0026279; 05/29/19 And by: marin v IGKAY Roll of Attorneys No. 52354 IBP Lifetime No. 06276; 01/09/07; RSM PTR No. A-5400918; 01/18/22; Taguig City MCLE Compliance No. VI-0027695; 04/22/19 And by: Z LEB M. GATMAITAN Roll/of Attoi lo. 59772 IBP Lifetime No. 010566; 02/03/12; PLM PTR No, A-5400991; 01/18/22; Taguig City MCLE Compliance No. VI-0023118; 04/24/19 And by: DANIE ANNA C. GAITE Roll of rys No. 75309 IBP No. 177883; 02/10/22; Makati City PTR No. A-5400948; 01/18/22; Taguig City MCLE Compliance No. VII-0014050; 03/30/22 Copy furnished: Attys. Ronald Ofivar Solis and BY REG. MAIL. RE 602 005 262 27 Rico A. Limpinco- Oo ean NCA Solis & Medina Law Offices Counsel for Plaintiffs11® Floor, Philippine Stock Exchange Centre East Tower, Exchange Road Ortigas Business Centre, Pasig City Atty, Oswaldo A. Macadangdang Macadangdang Law Office Ground Floor, Door 2 Perica Tulip Townhouse Tulip Drive, Matina Davao City Atty. Benjamin B, Cuanan 2nd Floor, Dinopol Building South Osmefia Street General Santos City Atty. Salvador Bijis R-2, UF Torre Building San Pedro-Anda Strests Davao City Callanta and Partners Law Firm 40 West Avenue 1104 Quezon City Angara Abello Concepcion Regala & Cruz ACCRALAW Tower 2m Avenue comer 30" Street Crescent Park West Bonifacio Global City Taguig City Sycip Salazar Hernandez & Gatmaitan 7 Floor, SSHG Law Centre 105 Paseo de Roxas BY EMAIL/ REG. MAIL / COURIER RE 602.005 259 zz (EU BY EMAIL/REG. MAIL/COURIER, RE 602.005 248 zz OT BY REG. MAIL/COURIER RE 802.005 234 2 Hcy BYREG.* 0" or Wath aATa y BY EMAIL/REG. MAIL/COURIER RE 802.005 214 27 {0 TUE RE 802.005 205 22 HCI | XURTBR: Makati City Cruz Marcelo & Tefiefrancia BY EMAIL/REG, MAIL/COURIER 9th, 10th, 11th & 12th Floors, One Orion Re 607005 165 27 11th Avenue comer University Parkway Sa maa en Bonifacio Global CityTaguig City 1634Explanation under Section 11, Rule 13 Due to distance, number of parties and lack of available messenger personnel, personal service to the other parties is not practicable. Thus, this pleading is filed with the Honorable Court by registered mail and email, and served on the other parties by email, registered mail and courier. DANIE) Cc. GAITEREPUBLIC OF THE PHILIPPINES ) TAGUIG CITY, METRO MANILA )S.S. AFFIDAVIT OF FILING AND SERVICE 1, Noel Roquero, a messenger of Quisumbing Torres with office address at 16th Floor, One/NEO Building, 26" Street comer 3° Avenue, Crescent Park West, Bonifacio Global City, Taguig City, Metro Manila, after being duly sworn, depose and state: 1. That on 15 June 2022, I served copies of the following pleading/paper: MANIFESTATION (RE FILING AND SERVICE OF FORMAL OFFER OF EVIDENCE) to the following parties at the following addresscs, in relation to CIVIL CASE NO. 5617, entitled " BERNABE NAVIDA, ET AL., Plaintiffs versus SHELL OIL COMPANY, ET AL., Defendants”, pending before the REGIONAL TRIAL COURT BRANCH 37, GENERAL SANTOS CITY pursuant to Sections 3,4,5, and 15 of Rule 13 of the Rules of Court, as amended, by depositing them with the post office, in a sealed envelope, plainly addressed to the party/attorney at his/her office/residence address, with postage fully prepaid, as evidenced by the registry receipts, and with instructions to the postmaster to return the mail to the sender after ten (10) calendar days if undelivered. 2. That the addresses are as follows: Attys. Ronald Olivar Solis and BY REG, MAIL Rico A. Limpinco Solis & Medina Law Offices Counsel for Plaintifts 1th Floor, Philippine Stock Exchange Centre East Tower, Exchange Road Ortigas Business Centre, Pasig City ‘Atty. Oswaldo A. Macadangdang BY EMAIL / REG. MAIL / COURIER Macadangdang Law Office Ground Floor, Door 2 erica Tulip Townhouse Tulip Drive, Matina Davao City Atty. Benjamin B, Cuanan BY EMAIL/REG. MAIL/COURIER 2nd Floor, Dinopol Building South Osmefia Street General Santos City Atty. Salvador Bijis BY REG. MAIL/COURIER R.2, 2F Torre Building San Pedro-Anda Streets Davao City Callanta and Partners Law Firm BY REG. MAIL 40 West Avenue 1104 Quezon City Angara Abello Concepcion BY EMAIL/REG. MAIL/COURIER Regala & Cruz ACCRALAW Tower 2nd Avenue corner 30th Street Crescent Park West Bonifacio Global City Taguig CitySycip Salazar Hernandez BY EMAIL/REG. MAILICOURIER & Gatmaitan Tth Floor, SSHG Law Centre 105 Pasco de Roxas Makati City Cruz Marcelo & Tefiefrancia BY EMAIL/REG. MAIL/COURIER 9th, 10th, 11th & 12th Floors, One Orion 11th Avenue comer University Parkway Bonifacio Global CityTaguig City 1634 3. That the pleading/paper mentioned above is also being filed with the REGIONAL TRIAL COURT BRANCH 37, GENERAL SANTOS CITY on 15 June 2022, pursuant to Section 16, Rule 13 of the Rules of Court, as amended, by depositing the same with the post office, in a sealed envelope, plainly addressed to the REGIONAL TRIAL COURT BRANCH 37, GENERAL SANTOS CITY, with postage fully prepaid, as evidenced by the registry receipts, and with instructions to the postmaster to retum the mail to the sender after ten (10) calendar days if undelivered, ral 4 jant SUBSCRIBED AND SWORN to before me by Noel Roquero, who is personally known to me to be the same person who presented the foregoing instrument and signed the instrument in my presence, this 15 June 2022, at Taguig City, Metro Manila, affiant further exhibiting to me, as competent evidence of his identity, UMID LD. with number 0111-7903611-1. Taguig City, Metro Manila, 15 June 2022. NRY 0 a oy Doc. No. “7. 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