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Formal Offer of Documentary Exhibits - Mendoza V Dela Cruz LTFRB

This document is a formal offer of documentary exhibits submitted by the complainant's counsel in an administrative case between Nida Mendoza and Reynaldo Dela Cruz before the Land Transportation Franchising and Regulatory Board Regional Office No. 2. It offers three exhibits: A) the complaint affidavit to prove the allegations in the administrative complaint and respondent's liability, B) a Western Union receipt to prove the complainant paid 5,000 pesos to Julieta Teano for help getting a franchise through the respondent, and C) an LBC receipt to prove another 5,000 peso payment to Teano for the same purpose. The counsel requests the exhibits be admitted for the stated purposes.

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Ed Armand Ventolero
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561 views3 pages

Formal Offer of Documentary Exhibits - Mendoza V Dela Cruz LTFRB

This document is a formal offer of documentary exhibits submitted by the complainant's counsel in an administrative case between Nida Mendoza and Reynaldo Dela Cruz before the Land Transportation Franchising and Regulatory Board Regional Office No. 2. It offers three exhibits: A) the complaint affidavit to prove the allegations in the administrative complaint and respondent's liability, B) a Western Union receipt to prove the complainant paid 5,000 pesos to Julieta Teano for help getting a franchise through the respondent, and C) an LBC receipt to prove another 5,000 peso payment to Teano for the same purpose. The counsel requests the exhibits be admitted for the stated purposes.

Uploaded by

Ed Armand Ventolero
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

LAND TRANSPORTATION FRANCHISING AND REGULATORY


BOARD
Regional Office No. 2
Carig Sur, Tuguegarao City, Cagayan

NIDA MENDOZA
Complainant

Administrative Case No.


2019-01 for Grave
Misconduct
-versus-

REYNALDO DELA CRUZ


Respondent
x-----------------------------------x

FORMAL OFFER OF DOCUMENTARY EXHIBITS

TO THIS HONORABLE OFFICE, complainant by counsel


most respectfully submits the foregoing formal Offer of
Documentary Exhibits, pursuant to an Order of the Honorable
Office, to wit:

Exhibi Nature Purpose for which it was offered


t
A Complaint- To prove the material allegations stated
Affidavit in this administrative complaint and
that the herein respondent is liable for
Grave Misconduct;

Western Union To prove that the complainant has given


B Receipt No. a money amounting to P5,000.00 to
206-226-6954 Julieta Teano with the promise that her
of a remittance franchise application will be granted
to Julieta through the intervention of the
Teano respondent;
C LBC OR No. To prove that the complainant has given
10403838406 another sum of money amounting to
3 P5,000.00 to Julieta Teano with the
promise that her franchise application
will be granted through the intervention
of the respondent
PREMISES CONSIDERED, plaintiffs most respectfully pray of
this Honorable Office to ADMIT the foregoing documentary exhibits
for the purpose for which they are offered. Other reliefs are likewise
prayed for.

Tuguegarao City, Cagayan, 12January2021.

ATTY. ED ARMAND T. VENTOLERO


Roll of Attorneys No. 68849
PTR No. 10891832/01/06/2021
IBP No. No Official Receipt Yet
MCLE Compliance Certificate No. VI-0018760
Counsel for the Complainant

Copy Furnished:

ATTY. BONIFACIO ALBINO PATTAGUAN, JR.


Counsel for the Respondent
Caggay, Tuguegarao City, Cagayan

NOTICE OF FILING AND SERVICE

ATTY. JINKY ZIPAGAN


Attorney IV/ Hearing Officer
LTFRB-Regional Office II
Tuguegarao City, Cagayan

Greetings:

Please take notice that the undersigned counsel files the


foregoing Formal Offer of Documentary Exhibits for the
complainant.

Copy of the foregoing pleading was filed and served through


personal service.
ATTY. ED ARMAND T. VENTOLERO

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