REPUBLIC OF THE PHILIPPINES METROPOLITAN TRIAL COURT Quezon city Branch 174 JERRY MELIN, Plaintiff,

-versus-

SPECIAL CIVIL CASE No. 30921 FOR: INTERPLEADER

BETH ACOSTA-LOT and REGINA NATUTO Defendant.

x----------------------------------------------------------------------------------------------------------------------------x COMPLAINT

COMES NOW the plaintiff by the undersigned attorney, and unto this Honorable Court, respectfully avers: 1. That the plaintiff is all of legal age, and residents of #7 Houston St., Racquet subdivision, Quezon city, Philippines; 2. That on or about 13, January, 2014, the plaintiff found certain Lou Boatin handbag worth about one hundred and ninety thousand pesos (Php 190,000.00) in the vacant lot next to the plaintiffs house in the aforementioned address herein; 3. That the said handbag is now in the possession of the plaintiff; 4. That on or about 20, January, 2014, at about eight oclock in the morning, Beth AcostaLot, a neighbor, approached the plaintiff and claimed that she had owned the said handbag in question; 5. That on the same day, but at about two oclock in the afternoon, Regina Natuto also approached the plaintiff and claimed that the same handbag in question was hers; 6. That the plaintiff did not give the handbag to any of them as they did not provide any proper proof that it was theirs, and that the plaintiff is still in the possession of said handbag; 7. That both plaintiffs had contacted Police authorities to take the said handbag away without any search and seizure order presented to me; 8. That the plaintiff brings this action against the conflicting claimants to compel them to interplead and litigate their several claims among themselves. WHEREFORE, it is respectfully prayed of this Honorable Court: a. to issue an order summoning the defendants to interplead with one another so as to determine their respective rights and claims; b. to issue a Temporary Restraining order against the seizure of the said handbag by the Police authorities;

c. to allow plaintiff to recover his expenses for safekeeping, and the costs of this suit, to be charged as first lien upon the subject matter of this action.

Quezon city, 17, February, 2014

Atty. Lawrence Emmanuel Solis Unit A-1, Graham Bldg. Makati City, Philippines

VERIFICATION WITH CERTIFICATION OF NON-FORUM SHOPPING

Republic of the Philippines) ) S.S.

I, Jerry Melin, of Legal age both of legal age, Filipinos, and residing at #7 Houston St., Racquet subdivision, Quezon city, Philippines, after having been duly sworn to in accordance with law hereby depose and state that: 1. I am the petitioner in the above-captioned case and caused the preparation of the foregoing petition, the contents of which we have read, and are true and correct to the best of my personal knowledge; 2. I have not commenced any action of filed any claim involving the same issues in any court, tribunal or quasi-judicial agency and, to the best of our knowledge, no such other action or claim is pending therein; 3. If there be such action or claim, undertake to render this Honorable Court a complete statement of the present status thereof, and/or if I should thereafter learn of the same or similar action or claim that has been filed or is pending, I undertake to report such fact within five (5) days therefrom to this Honorable Court.

IN WITNESS WHEREOF, I have hereunto set my hand this 17th day of february 2014, in Makati City, Philippines .

Jerry Melin Petitioner Drivers License No. D04-03-002800 expires on 2011-12-13

SUBSCRIBED AND SWORN TO BEFORE ME at the date and place above-written, affiants showed to me their identification card as shown above.

Doc. No. ________; Page No. ________; Book No. ________; Series of 2014.

Atty. Lawrence Emmanuel Solis Counsel for the Plaintiff PTR No. B.C. IBP No, :B.C. Roll No. : Makati Unit 1331, MARC Tower Rufino, Makati City