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REPUBLIC OF THE

PHILIPPINES NATIONAL
CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH 49, CITY OF MAKATI

Hottie Table Inc. (HTI) represented


by its President, Nancy M. Ramsey
Plaintiff,
‐versus‐ Civil Case No. 09‐23654
(For: Sum of Money)
William Toh Go
Defendant.
xx‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐xx

FORMAL OFFER OF EVIDENCE

Plaintiff, through counsel, respectfully offers in evidence the following exhibits:

EXHIBIT DESCRIPT ION PURP


OSE
Exhibit “1” The Board ution dated 28 This will be used to show the legal
Resol April 2006 indicating that HTI’s standing and capacity of Mrs.
President, Mrs. Nancy M. Ramsey to bring the present suit in
Ramsey, is authorized to behalf of HTI.
represent the petitioner
Corporation.
Exhibit “2” Promissory dated 11 March Such promissory note will be used
Note 2005 in the amount of five as evidence of the indebtedness of
hundred thousand five hundred herein defendant Mr. William Toh
and fifty pesos (PhP Go.
500,550.00)
Exhibit “2‐A” Signature of r. William Toh Go In order to thenticate and
M fully au affirm the execution and handwriting
of the defendant in the aforesaid
promissory note.

Exhibit “2‐B” Demand dated 15 May 2005 This is to serve as proof of demand
letter sent by Plaintiff HTI’s counsel on the defendant’s obligation under
and was duly received by the the above‐mentioned promissory
defendant. note.
Exhibit “3” Promissory dated 16 June Such promissory note will be used
Note 2005 in the amount of as evidence of the indebtedness of
Seven Hundred Fifty herein defendant Mr. William Toh
Thousand Pesos Go.
(P750,000.00)
Exhibit “3‐A” Signature of r. William Toh Go In order to thenticate and
M fully au affirm the execution and handwriting
of the defendant in the aforesaid
promissory note.

Exhibit “3‐B” Demand dated 14 August This is to serve as proof of demand


letter 2005 sent by Plaintiff HTI’s on the defendant’s obligation under
counsel and was duly received the above‐mentioned promissory
by the defendant. note.

Exhibit “4” Final demand ter dated 15 This is to serve as a proof of the
let December 2005 on all the final demand before resort to court
promissory notes issued by action was made.
the defendant.

Exhibit “5” Registry Card addressed to This will show that service of
Return Defendant William Toh summons was duly served upon
Go. the defendant.

Exhibit “5‐A” Registry n Card signed by This will serve as an


Retur Mr. Pedro Domingo. acknowledgement of the defendant
of the service of summons upon
him
Exhibit “6” Letter of the endant William This will be used as evidence of
def Toh Go to Plaintiff HTI dated the defendant’s admission of
19 December 2005 through indebtedness to the Plaintiff.
registered mail recognizing his
indebtedness under the aforesaid
promissory notes.

Exhibit “6‐A” Registry card indicating This will be used to indicate the
return that such letter was duly received authenticity of the letter received by
by the corporate secretary of the Plaintiff.
HTI.

WHEREFORE, it is most respectfully prayed that the foregoing exhibits presented during the

trial of the instant case be admitted in evidence.

Other reliefs just and equitable are likewise prayed for.

Muntinlupa City for Makati City, 30 January 2009.


5 DULAY, DULAY AND DULAY LAW OFFICE
Counsel for the Plaintiff
Berlay Building, Awhag Subd, Bacaca, Davao City
By:

10 [sgd] ATTY. ADEL B. DULAY


Roll of Attorneys No. 45454; I
BP No .09876; issued 01/05/2019; IBP Davao City
PTR No.06789; issued 01/10/2019; Davao City

PAGE 3
REPUBLIC OF THE PHILIPPINES )
CITY OF DAVAO ) S.S.

5 VERIFICATION AND CERTIFICATION


AGAINST FORUM SHOPPING

I, SAM O. KHAN, Filipino, of legal age residing at 25 Lilac Street,


Perfect Homes Subdivision, Digos City, after being sworn to in accordance
10 with law, deposes and says that:
1. I am the Petitioner in the above-entitled case;
2. The facts stated in the above petition are true and correct to the best of
my knowledge and authentic records;
3. I have not commenced any action or filed any claim involving the
15 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 days
20 from notice to the court or where the petition has been filed.

Davao City, Philippines, this 31st day of January 2020.

[sgd] SAM O. KHAN


25 Affiant

SUBSCRIBED AND SWORN to before me in the City of Davao this


31st day of JANUARY, 2020, by SAM O. KHAN, who has satisfactorily
proven his identity to me through his LTO Driver’s license ID bearing his
30 photograph and signature and with ID No. L0984662-4, that he is the same
person who personally signed the foregoing document before me and
acknowledged that he executed the same.

WITNESS MY HAND AND SEAL this 31st day of January,


35 2020 at Davao City, Philippines.

40 ATTY. MARY BESSADEL B. DULAY


Notary Public for Davao City
Doc. No._____; Notarial Commission No. 12-2019
Page No. _____; Commission expires on December 31, 2021
Roll of Attorneys No. 45454;
Book No. 1 ; IBP No .09876; issued 01/05/2019; IBP Davao City
Series of 2020; PTR No.06789; issued 01/10/2019; Davao City
Berlay Bldg., Awhag Subd. Bacaca Road, Davao City
45

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