Sales, Steffi

Evardone, Philip*

Republic of the Philippines

National Capital Judicial Region
REGIONAL TRIAL COURT
Branch 30, Makati City
RE: PROBATE OF THE HOLOGRAPHIC
WILL OF MICHAEL JACKSON.,
SP PROC. No. 0023
JANET JACKSON,
Petitioner,
x ------------------------------------ x

PETITION

COMES NOW, the PETITIONER, by counsel, respectfully states

that:

1. Petitioner is a Filipino citizen residing at 4 One Rockwell, Rockwell

Drive, Makati City and the widow of the deceased Michael Jackson.
2. On 1 November 2014, Michael Jackson died in their residence in Makati
City where he last resided.
3. That on 2 September 1999, the decedent executed a holographic will in
his own handwriting and in English, a language known to him.
3.1. A copy of the will is attached as ANNEX A.
4. The handwriting of the testator on the said will may be attested to as his
by his butler for 47 years, Gerard Butler.

Sales, Steffi
Evardone, Philip*

5.1. The probable value of the condominium is 7million (7,000,000.00)

Pesos.
6. The deceased left no debts.
7. The deceaseds only heir is herein petitioner.

WHEREFORE, it is respectfully prayed that after due notice and

publication this Honorable Court fix the date for the probate of the
holographic will and that letters of administration be issued in favor of the
herein petitioner and thereafter adjudicate the properties of the deceased in
accordance with the said holographic will.

Makati City, 1 December 2014

(SGD.) ROGER A. NADAL

Counsel for Defendant
Address: Unit 45, Rockwall Bldg.
Rockwell Drive, Makati City
Roll No. 41890
PTR No. 633542; 1/10/80; Makati City
IBP No. 888308; 12/20/79; Makati City Chapter

Copy furnished:
ATTY. BILBO BAGGINS
Counsel for Defendant
215 Salcedo Street,
Legaspi Village Makati City,
Metro Manila Philippines, 1203

Sales, Steffi
Evardone, Philip*

REQUEST FOR & NOTICE OF HEARING

THE BRANCH CLERK OF COURT
Regional Trial Court
Makati City, Branch 30
Please submit the foregoing Motion to the Court for its consideration
and approval immediately upon receipt hereof and kindly include the same
in the courts calendar for hearing on 14 January 2014 at 9:00 a.m.

ATTY. BILBO BAGGINS

Counsel for Defendant
215 Salcedo Street,
Legaspi Village Makati City,
Metro Manila Philippines, 1203
Madam:
Please be informed that the undersigned counsel has set the foregoing
motion for hearing on 14 January 2014, 9:00am. for the consideration of the
Honorable Court or soon thereafter as counsel may be heard.

(SGD.) ROGER A. NADAL

Counsel for Defendant
Address: Unit 45, Rockwall Bldg.
Rockwell Drive, Makati City
Roll No. 41890
PTR No. 633542; 1/10/80; Makati City
IBP No. 888308; 12/20/79; Makati City Chapter

Sales, Steffi
Evardone, Philip*

VERIFICATION AND CERTIFICATION

AGAINST FORUM SHOPPING

I, Janet Jackson, of legal age and with residence at 4 One Rockwell, Rockwell
Drive, Makati City, after having been duly sworn, depose and say:
1. That I am the petitioner in the above entitled petition for probate of a
holographic will;
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 and/or based on authentic
records.
That I have not theretofore commenced any action or filed any claim involving the
same issues in any court, tribunal, or quasi-judicial agency and, to the best of his
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 that fact within five (5) days therefrom to the court wherein
the aforesaid complaint or initiatory pleading has been filed.

(SGD.) JANET JACKSON

SUBSCRIBED AND SWORN TO before me this 2nd day of January 2014,

in Makati City, Philippines, exhibiting to me his Community Tax Certificate No.
00835519 issued on January 24, 2010 at Makati City.

(SGD.) ROGER A. NADAL

Counsel for Defendant
Address: Unit 7G, Rockwall Bldg.
Ayala Avenue, Makati City
Roll No. 41890
PTR No. 633542; 1/10/80; Makati City
IBP No. 888308; 12/20/79; Makati City Chapter

Sales, Steffi
Evardone, Philip*

EXPLANATION
Service of this Answer is by registered mail instead of personal service
because the offices of undersigned counsel and counsel of the adverse party
are distantly located and because of lack or inadequate messengerial aide to
make personal service.
(SGD.) ROGER A. NADAL

AFFIDAVIT OF SERVICE BY REGISTERED MAIL

I, Lorde Voldemort, of legal age and having been duly sworn depose
and say:
That I am the messenger of Atty. Nadal, counsel for defendant in the
case entitled re: probate of the holographic will of Michael Jackson
Special Proceedings No. 0023, and that such messenger I served upon the
counsel of adverse party and other parties, the pleading filed in said case, as
follows:
Atty. Nadal, counsel for defendant by registered mail by depositing
the copy in the post office in sealed envelope, plainly addressed to the
counsel at his office, with postage fully prepaid, and with instruction to the
postmaster to return the mail to the sender after ten days if undelivered, this
16th day of January 2014, as shown by Registry No. 23390 dated 16 January
2014 of the post office of Makati City.
IN WITNESS WHEREOF, I have signed this affidavit this 4th day of
Januray at Makati City.

(SGD.) LORDE VOLDEMORT