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Petitioner,
- versus CIERRA EDRALIN-NISHIHARA
AND NENITA EDRALIN,
Respondent,
x---------------------------x
PETITION
COMES NOW the Petitioner, by the undersigned attorney, and unto this Honorable
Court, respectfully avers:
1. Petitioner is of legal age, married and a resident of Las Vegas, Nevada, while
respondent Cierra Edralin (Cierra) is also of legal age, married, and is currently
residing in Tokyo, Japan;
2. A child aged 9, whose name is Joshua Santillian, was born out of wedlock between
petitioner and respondent.
3. Sometime in 1999, petitioner travelled to Las Vegas, Nevada, to work at the Piercy
Bowler Taylor & Kern accounting firm, leaving the child in the care of respondent.
4. Sometime in April 2005, respondent left for Tokyo, Japan, and left the child in the
care of her mother, respondent Nenita Edralin (Nenita), who is of legal age and is
currently residing in Quezon City, Philippines.
5. Cierra got married to Takato Nishihara sometime after, and had sired with him two
children; she has also maintained her current residence ever since.
6. Petitioner avers that he has right of custody over the child; that Cierra had abandoned
their child upon her marriage to another; and that it is in the best interest of the minor
to be in the custody of petitioner and not that of Cierra or of Nenita.
I, RICO SANTILLIAN, of legal age and with residence at 1599 Quail Ridge Estates,
Henderson, Nevada, USA, after having duly sworn, depose and say:
1. That I am the petitioner in the above-entitled petition;
2. That I have caused the preparation of said petition;
3. That I have read the allegations therein contained and that the same are true and correct
of my personal knowledge or based on authentic records;
4. That I have not therefore 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 therein; and if I should thereafter learn that the same or similar
action or claim has been filed or is pending, I shall report the fact within five (5) days therefrom
to the court wherein the aforesaid complaint or initiatory pleading has been filed.
Witness my hand this 29th day of April, 2013 at Quezon City, Philippines.