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Formal Offer of Documentary Exhibits: Regional Trial Court
Formal Offer of Documentary Exhibits: Regional Trial Court
BALTAZAR B. BARTOLOME,
Defendant.
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FORMAL OFFER OF
DOCUMENTARY EXHIBITS
(For the Plaintiffs)
1
3. To prove that this
signature of plaintiff Andres P.
Soriano is markedly different
from the purported signature
of Andres P. Soriano in the
Deed of Absolute Sale dated
14 November 2011 allegedly
executed by Andres Soriano in
favor of defendant Baltazar
Bartolome.
4. As part of the
testimony of plaintiff Riolita P.
Soriano.
4. As part of the
testimony of plaintiff Riolita P.
Soriano.
2
by Baltazar Bartolome of the said Catulagan.
dated 27 November
2011; 2. To prove that in the
said “Catulagan”, only the
defendant Baltazar Bartolome
appears as a signatory.
3. As part of the
testimony of plaintiff Riolita P.
Soriano.
3. As part of the
testimony of plaintiff Riolita P.
Soriano.
3. As part of the
testimony of plaintiff Riolita P.
Soriano.
3
2015; 2. To deny that plaintiffs
appeared before Atty. Louella
Marie R. Agcaoili on 14
November 2011 relative to a
Deed of Sale dated 14
November 2011;
3. To deny the
genuineness and due
execution of the Deed of Sale
dated 14 November 2011.
4. As part of the
testimony of plaintiff Riolita P.
Soriano.
3. As part of the
testimony of plaintiff Riolita P.
Soriano.
PRAYER
WHEREFORE, it is most respectfully prayed that this
FORMAL OFFER OF DOCUMENTARY EXHIBITS be NOTED
and the exhibits attached hereto be ADMITTED for the
purposes that they are being offered.
RESPECTFULLY SUBMITTED.
By:
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ATTY. LUCKY M. DAMASEN
MCLE Compliance No. VI-0018789/2-20-2019
PTR No. 7012010/Santiago City/01-06-2020
Life Member IBP No. 021277/IBP National Office,
Pasig City/01-05-2018
Roll No.37959/07-24-92
&
NOTICE
GREETINGS:
Copy furnished:
Atty. Grace A. Manaloto
Counsel for the Defendant
Manaloto Law Office
National Highway, Alibagu, City of Ilagan
EXPLANATION
(Pursuant to Section 11; Rule 13
of the 1997 Rules of Civil Procedure)
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The original copy of this Pleading/Motion to which this
explanation is attached was: