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IN THE COURT OF THE PRL.

DISTRICT JUDGE, ONGOLE


I.A.No. /2017 in M.V.O.P.No.388/2016

Between:-
(1) Potthuri Nagaveni
W/o.Late Srinivasa Rao, Hindu,
Aged about 33 years, House Wife,
(2) Potthuri Abhinay Chowdari,
S/o.Late Srinivasa Rao, Hindu,
Aged about 14 years, Student,
(3) Potthuri Venkata Sai Swetha Chowdari
D/o. Late Srinivasa Rao, Hindu,
Aged about 12 years, Student,
Petitioners Nos.2 and 3 are being minors,
Rep by their mother, natural guardian Potthuri Nagaveni.
(4) Potthuri Venkata Rao
S/o. Venkaiah, Hindu,
Aged 65 years,

All are residents of D.No.2-47,


Doddavarappadu Village,
Maddipadu Mandal, Prakasam District. .. Petitioners

AND

(1) Srinivasulu K S/o.Venkata Subbaiah,


Aged about 47 years,
R/o Sri Vivekanada Part Street,
Kavali Town, Nellore District.

(2) DR S Kalyan Kumar,


S/o. Nageswara Rao
ENT Specialist, Anjaiah Road,
Ongole, Prakasam District.

(3) National Insurance Co., Ltd.,


Rep. by its Divisional Manager,
Vijaya Complex, Dhavari Thota,
Ongole, Prakasam District. ..Respondents

PETITION FILED ON BEHALF OF THE PETITIONERS UNDER ORDER 7 R 14 (2) &


Sec.151 C.P.C
For the reasons stated in the accompanying affidavit this petitioners pray
the Honble Court may be pleased to condone the delay in filing documents and
grant permission to receive the documents to mark the same as exhibits (A1 to
A24) on behalf of the petitioners and pass such other reliefs, in the interests of
justice. Be pleased to Consider

ONGOLE,
Dt:-28-06-2017. ADVOCATE FOR PETITIONERS
IN THE COURT OF THE PRL. DISTRICT JUDGE, ONGOLE
M.V.O.P.No.388/2016

Potthuri Nagaveni & 3 others .. Petitioners

AND
Srinivaslu K & 2 others .. Respondents

AFFIDAVIT FILED U/S 139 C.P.C.


I, Potthuri Nagaveni, W/o. Late Srinivasa Rao, aged about 33 years,

Hindu, Resident of D.No.2-47, Doddavarappadu Village, Maddipadu Mandal,

Prakasam District, do hereby solemnly affirm and sincerely state as

follows:-

I am the deponent herein. The 2nd and 3rd petitioners are being minor

children and represented by me as natural guardian. The 4 th petitioner is

the father of my husband, Potthuri Srinivasa Rao. I am giving this affidavit

on behalf of all the petitioners. The above O.P is filed for compensation for

the death of my husband, Potthuri Srnivasa Rao, who died in a Motor

accident. By the time of filing O.P., I could not file the documents on my

behalf of as those documents are not in my custody. Now I obtained those

documents. It is just and essential to me to file those documents to prove

my case. There are now will full latches on my part in not filing those

documents by time of filing this O.P.

Hence I pray that the Honble Court may be pleased to receive the

documents on my behalf of by condoning the delay. Otherwise I will be put

to irreparable loss.

DEPONENT
Solemnly affirmed and signed before me the contents of the affidavit is read
over and explained in Telugu to the deponent and admitted her to be correct on
this the 28th day of June, 2017.

ADVOCATE, ONGOLE.
V.V.P.K
For:-Petitioners

IN THE COURT OF THE PRL.


DISTRICT JUDGE :: ONGOLE

I.A.No. /2017
M.V.O.P.No.388/2016

PETITION FILED ON BEHALF OF THE


PETITIONERS UNDER ORDER 7 R 14
(2) & SEC.151 C.P.C

FILED BY:-
Sri V.V.PAVAN KUMAR
ADVOCATE, ONGOLE
IN THE COURT OF THE PRL. DISTRICT JUDGE, ONGOLE
M.V.O.P.No.388/2016

Potthuri Nagaveni & 3 others .. Petitioners

AND
Srinivaslu K & 2 others .. Respondents

LIST OF DOCUMENTS FILED ON BEHALF OF THE


PETITIONERS

Exhibit-A1:-Attested copy of F.I.R. in Cr.No.104/2016 of Maddipadu P.S


Prakasam District U/s.337 I.P.C,
Exhibit-A2:-Attested copy of Alter Memo in Cr.No.104/2016 of Maddipadu
P.S., Prakasam District, altered section of Law from U/s.337 I.P.C
to U/sec.304-A I.P.C.,
Exhibit-A3:-Attested copy of Inquest Report relating to the deceased
Potthuri Srinivasa Rao,
Exhibit-A4:-Attested copy of P.M. Certificate relating to the deceased
Potthuri Srinivasa Rao,
Exhibit-A5:- Attested copy of M.V.I.Report,
Exhibit-A6:- Attested copy of Rough Sketch.
Exhibit-A7:-Attested copy of Charge Sheet in C.C. /2016 U/s.304-A IPC on the

file of Honble SPL. Mobile Magistrate Court, Ongole.


Exhibit-A8:-Discharge Summary (LAMA), dt.30-07-2016 relating to P.Srinivasa
Rao, issued by Sanghamitra Hospital, Ongole,
Exhibit-A9:-In Patient Final Bill, dt.03-07-2016 for Rs.2,34,270/- relating to
Pothuri Srinivasa Rao, issued by Sanghamitra Hospital, Ongole,
Exhibit-A10:-Bunch of Medical Reports 32 in number relating to the deceased
issued by Sanghamitra Hospital, Ongole,
Exhibit-A11:-Discharge Summary, dt.08-09-2016 relating to Pothuri Srinivasa
Rao, issued by Global Hosptials, Chennai,
Exhibit-A12:-Hospital Bill, for Rs.13,89,340/- relating to Pothuri Srinivasa
Rao, issued by Global Hosptials, Chennai,
Exhibit-A13:-Drugs & Disposables Bill for Rs.10,47,196=26 relating to relating

to Pothuri Srinivasa Rao, issued by Global Hosptials, Chennai,


Exhibit-A14:-Discharge Summary, dt.15-10-2016 relating to relating to Pothuri
Srinivasa Rao, issued by Nalluri Nursing Home, Ongole,
Exhibit-A15:-Consolidated Final Bill for Rs.3,09,698/- relating to Pothuri
Srinivasa Rao, issued by Nalluri Nursing Home, Ongole,
Exhibit-A16:-Discharge Summary, dt.21-10-2016 relating to Pothuri
Srinivasa Rao, issued by Lakshmi Super Speciality Hospital,
Ongole,
Exhibit-A17:-Attested copy of In-Patient Case Sheet, dt.23-10-2016 relating to
Pothuri Srinivasa Rao, issued by Dr.Pinnamaneni Siddhartha
Institute of Medical Sciences, General Hospital, Chinaoutapalli,
Gannavaram (M), Krishna District.
Exhibit-A18:-Patient Bill Details, dt.28-10-2016 for Rs.18,685/- relating to
Pothuri Srinivasa Rao, issued by Dr.Pinnamaneni Siddhartha
Institute of Medical Sciences, General Hospital, Chinaoutapalli,
Gannavaram (M), Krishna District,
Exhibit-A19:-Attested copy of Income Tax Returns for the Assessment Year
2013-14 relating to Sri Balaji Tractors, rep. by its Managing
Partner, Pothuri Srinivasa Rao,
Exhibit-A20:-Attested copy of Income Tax Returns for the Assessment Year
2014-15 relating to Pothuri Srinivasa Rao,
Exhibit-A21:-Attested copy of Income Tax Returns for the Assessment Year
2015-16 relating to Pothuri Srinivasa Rao,
Exhibit-A22:-Attested copy of Income Tax Returns for the Assessment Year
2016-17 relating to Pothuri Srinivasa Rao,
Exhibit-A23:-Bunch of CT-Scan Films - number relating to deceased, issued
by Global Hosptials, Chennai,
Exhibit-A24:-Bunch of CT-Scan Films - number relating to deceased issued by
Sangamithra Hospitals, Ongole.

Be pleased to Consider
ONGOLE,
Dt:-
ADVOCATE FOR PETITIONERS