NOTICE TO TAKE DEPOSITION UPON WRITTEN INTERROGATORIES

Office of the Solicitor General

Republic of the Philippines
Thru the Office of the City Prosecutor
Pasay City

Please take notice that on the 5th of December, 2017 the undersigned counsel for
Petition for Adoption of MARA RECIO in Civil Case No. 7569, entitled IN RE:
PETITON FOR ADOPTION OF MARA RECIO, RTC Branch 2 Pasay City, will take
the deposition of DR. ANA LUISA SANTOS, with address at 927 Sunny St. Manhattan,
New York USA, before Notary Public Atty. Minnie Mouse at the latter’s office at 846
Grand St. Manhattan, New York USA at 1 p.m., upon written interrogatories and to
continue from day to day at the same time and place until the interrogatories shall have
been completed. Attached are the written interrogatories.

Pasay City, December 6, 2017.

DISNEYLAND LAW OFFICE

Atty. Mickey H. Mouse
123 Honey St. Pasay City and
Upon DR. ANA LUISA S. SANTOS whose answers
To interrogatories are sought.

‘
Villanueva, Ralph H.
Practice Court I
11381612
 Republic of the Philippines
OFFICE OF THE CITY PROSECUTOR
Branch 1, Pasay City

IN RE: ADOPTION OF MARA RECIO,

Respondent,

-versus- Special Proceeding No. 645

LUCILA SANTOS,
Petitioner.

x------------------------------------------x

PETITION FOR LETTERS ROGATORY

PETITIONER, by counsel and to this Honorable Court respectfully alleges:

1. For the purpose of completing the petitioner’s adoption proceedings, so that a

just and fair decision may be rendered in the instant case, it is necessary that the
testimony of DR. ANA LUISA S. SANTOS, who is at present residing in the United
States at 927 Sunny St. Manhattan New York, USA., be taken by means of deposition upon
written interrogatories, attached herewith as Annex “A”, at the Philippine Consulate at its
offices in 546 Gary St. New York, U.S. before any Philippine consular representative
thereat, at such date and time as the latter may fix.

2. If the adverse party desires, he may serve cross-interrogatories to be filed in

court, so that the direct interrogatories and cross-interrogatories may both be sent to the
Philippine Consulate at the above-indicated address.

WHEREFORE, petitioner respectfully prays that an order issue directing the

Republic through the Office of the City Prosecutor in Pasay City to submit his written
interrogatories within ten(10) days from notice, requiring the clerk of court to issue letters
rogatory directed to the Philippine consular representative in the Philippine Consular
Office at Manhattan New York, U.S.A. to take the examination upon written
interrogatories attached herein, at such date and time as the consular representative may
schedule, with notice to the witness DR. ANA LUISA S. SANTOS to appear and testify
therein; and thereafter, to submit record of deposition to the Court which issued this
order, with notice to both parties.

Pasay City, December 6, 2017.

DISNEYLAND LAW OFFICE

Atty. Mickey H. Mouse
123 Honey St. Pasay City
Roll No. 45262
IBP No. 722, issued on January 1, 2016, Pasay City
PTR No. 8746 issued on January 5, 2017, Pasay City

Villanueva, Ralph H.
Practice Court I
11381612
 Copy furnished:

Office of the Solicitor General

Republic of the Philippines
Thru the Office of the City Prosecutor
Pasay City

AFFIDAVIT OF SERVICE BY REGISTERED MAIL

I, Chuckie Bride, of legal age and having been duly sworn depose and say:

That I am the messenger of Atty. Mickey H. Mouse or the law firm of DISNEYLAND LAW FIRM,
counsel for petitioner MARA RECIO in the case entitled “IN RE: PETITION OF MARA RECIO,
Civil Case No. 7569 and that such messenger I served upon the counsel of adverse party and other
parties, the petition filed in said case, as follows:

Atty. Juan de la Cruz, counsel for defendant by registered mail by depositing the copy in the post
office in sealed envelope, plainly addressed to the party or 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 7th day of December, as shown by Registry No. 847 dated of the post office of
Pasay.

IN WITNESS WHEREOF, I have signed this affidavit this 7th day of December, 2017 at
Pasay.

Chuckie Bride
Affiant

SUBSCRIBED AND SWORN TO before me this 7th of December 2017 in Pasay City
Metro Manila Philippines, affiant exhibiting to me his valid proof of identification.

Atty. Light
Notary for Pasay City
Unit 63 Ilaw St. Pasay City
IBP No.8467; 01-8-2016
PTR No. 863; 03-27-2015
Roll No. 846;05-6-2017
MCLE No. 763-74

Doc No. 84
Page No. 75
Book No. 74
Series of 2017

Villanueva, Ralph H.
Practice Court I
11381612
 WRITTEN INTERROGATORIES TO ANA LUISA SANTOS

1. Please state your full name, your present home address, your profession and business
address, and the title you hold with the petitioner, or the capacity in which you are
associated with the petitioner.

Answer:

2. Please state the circumstances when MARA RECIO was born from her natural mother.

Answer:

3. Please state the relationships you have with MARA RECIO with your other siblings.

Answer:

4. Describe the relationship you have previously with MARA RECIO in relation to your
mother and her natural mother.

Answer:

5. Please state the circumstances that led MARA RECIO to be adopted by your family.

Answer:

6. Please state the circumstances from the day MARA RECIO was born up to the moment
she was sent to school.

Answer:

Villanueva, Ralph H.
Practice Court I
11381612
Villanueva, Ralph H.
Practice Court I
11381612