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Republic of the Philippines

7th Judicial Region
REGIONAL TRIAL COURT
Branch ___
Cebu City

LUKE DEIDER, Civil Case No. _____________

  Plaintiff, FOR: Collection for Sums of
Money with Damages

-versus-

SURIGAO ISLAND SALES

CORPORATION and
ARIANNE SANTOS,
         Defendants.
x -------------------------------------------x

DEFENDANT’S EX-PARTE MOTION FOR WRITTEN INTERROGATORIES

DEFENDANTS, Surigao Island Sales Corporation (“SISC” for brevity)

and Arianne Santos (“Arianne” for brevity), through the undersigned
counsels, and unto this Honorable Court, most respectfully requests,
for the plaintiff, Luke Deider to answer the following:

A. INSTRUCTIONS

1. Pursuant to Rule 25 of the Rules of Court, you are requested

to answer within fifteen (15) days the following
interrogatories;

2. Also in accordance with Rule 25 Section 2, you shall file and

serve a copy to the party submitting the interrogatories, the
answers within fifteen (15) calendar days after service
thereof, unless the court on motion and for good cause
shown, extends or shortens the time;

3. If in answering these interrogatories, you encounter any

ambiguities in construing a question, instruction, or
definition, set forth the matter deemed ambiguous and the
construction used in writing;
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B. DEFINITIONS:

4. Where the name or identity of a person is requested, please

state the full name, home address, and also business
address, if known;

5. Unless otherwise indicated, these Interrogatories refer to

time, place, and circumstances of the occurrence mentioned
or complained of in the pleadings;

6. Where knowledge of information or possession of a party is

requested, such request includes knowledge of the party’s
agents, representatives and, unless privileged, his attorneys.
When answer is made by a public or private corporation or a
partnership or association, state the name, address, and title
of the person supplying the information, and making the
affidavit, and the source of his information;

7. The pronoun “you” refers to the party whom these

Interrogatories are addressed, and the persons mentioned in
paragraph number six (6);

C. INTERROGATORIES:

8. Please state the name, law firm address and your

relationship with the person who helped you in the
preparation of this document;

9. What is your relationship with the defendant SISC?

10. What is your relationship with the defendant Arianne?

11. What is your relationship with Rona Santos?

12. What is the defendant SISC’s relationship with Arianne?

13. What is the defendant Arianne’s relationship with SISC?

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14. What is the defendant Arianne’s relationship with Rona

Santos?

15. Where did you get a copy of the General Information Sheet
of Defendant SISC?

16. What is

Respectfully submitted this 30th day of March 2020 at Cebu City.

KAYE & FRIENDS LAW OFFICE

Counsels for Surigao Island Sales Corporation
And Arianne Santos
6/F Cebu Holdings Center Building
Cebu Business Park (Ayala)
6000 Cebu City, Philippines
Telephone: (032) 260-5490 to 95
Facsimile: (032) 260-5496
Email: info@kaflaw.com

BY: COUNSELS FOR DEFENDANTS

ATTY. KAYE C. ARENDAIN

Roll No. 5000
IBP No. 011 – Lifetime
PTR No. 70 - 1/2/2020 Cebu
MCLE Compliance No. IV-001234
Issued on January 12, 2020
Telephone: (032) 260-5491
Email: kayearendain@kaflaw.com

ATTY. JOSHUA Z. BAGUIO

Roll No. 5001
IBP No. 012 – Lifetime
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PTR No. 71 - 1/2/2020 Cebu

MCLE Compliance No. VI-001235
Issued on January 12, 2020
Telephone: (032) 260-5492
Email: joshuabaguio@kaflaw.com

ATTY. PSYCHE A. CASTILLON

Roll No. 5003
IBP No. 013 – Lifetime
PTR No. 72 - 1/2/2020 Cebu
MCLE Compliance No. IV-001236
Issued on January 12, 2020
Telephone: (032) 260-5493
Email: psychecastillon@kaflaw.com

ATTY. SHAIRA M. TABORADA

Roll No. 5004
IBP No. 014 – Lifetime
PTR No. 70 - 1/2/2020 Cebu
MCLE Compliance No. VI-001237
Issued on January 12, 2020
Telephone: (032) 260-5494
Email:
shairataborada@kaflaw.com

ATTY. KIMBERLEY P.
URTIZBEREA
Roll No. 5005
IBP No. 015 – Lifetime
PTR No. 70 - 1/2/2020 Cebu
MCLE Compliance No. VI-001238
Issued on January 12, 2020
Telephone: (032) 260-5495
Email: kimberleyurtizberea@kaflaw.com

Copy Furnished via Registered mail:

MCDAS LAW FIRM Registry Receipt No. 123456

c/o ATTY. EMILY GRACE ACHAY PhilPost
Counsels for Plaintiff Date: March 30, 2020
Level 2, The Walk,
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Abad Street, Cebu City, Cebu 6000

Republic of the Philippines)

City of Cebu.......................)S.S.

AFFIDAVIT OF SERVICE

I, Rico J. Puno, of legal age, Filipino, single and a resident of Dapitan,

Cordova, Cebu, Philippines, after having been duly sworn to in accordance
with law, depose and and state:

1. That I am employed as a messenger of Atty. Kaye C. Arendain of KAF

Law, with office address 6/F Cebu Holdings Center Building, Cebu
Business Park (Ayala), Cebu City, Philippines

2. That on March 9, 2020, I served a copy of the ANSWER in Civil Case

No. _____ entitled “Luke Deider v. Surigao Island Sales Corporation
and Arianne Santos” to MCDAS Law Firm c/o Atty. Emily Grace Achay,
by registered mail in accordance with Section 17 of Rule 13 of the
2019 Proposed Amendments to the 1997 Rules of Civil Procedure;

3. That a copy of the said answer was placed in a sealed envelope,

plainly addressed to the plaintiffs’ counsel at his office with postage
fully paid, as evidenced by Registry Receipt No. 123456 attached, and
that the registry return card will be filed immediately to the court
upon receipt by the sender;
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4. That the post master is given instructions to return the mail to the
sender after ten (10) days if undelivered.

IN WITNESS WHEREOF, I have hereunto set my hands on this 30th day of

March 2020 in Cebu City, Philippines.

Rico J. Puno
Prof. Driv. Lic. # G01-123456-78
Date issued: 1-1-2020

SUBSCRIBED AND SWORN to before me, this 30th day of March

2020, affiant exhibiting to me his Professional Drivers License as shown
above below his name. Further, I hereby certify that Affiant is personally
known to me and that he has executed the foregoing verification in my
presence.

KIMBERLEY URTIZBEREA

Doc No. 4; Notary Public of Cebu City

Page No. 1; Notarial Commission 505-L
Book No. 1; Until December 31, 2020
Series of 2020 PTR # 123456, Cebu City, 1-3-2020
IBP-Life 04719 OR # 553372, Cebu, 1-3-03
TIN-123-456-789, Roll of Attys. # 12345
Rizal St., Poblacion, Cebu City
MCLE Compliance # VI-0016211
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Valid until 4/14/22

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