REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL

REGION REGIONAL TRIAL COURT
BRANCH 60, MAKATI CITY
DAVID FRANCOIS L. SAMIO
MARCO ANTONIO L. SAMIO AND
ERIK L. SAMIO,
Plaintiffs,
-versus-

Civil Case No. L-98765

For: Partition

VLADIMIR BARRACK L. SAMIO, as represantive of Heirs of Dona Nena Samio,

Defendant,
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MOTION TO INTERVENE
COMES NOW the intervenors, MR. AND MRS. RENATO ORTIZ, by his undersigned
counsel and to this Honorable Court respectfully prays that they be permitted to file a
complaint in intervention in the aboveentitled case, for the following reasons:
1. That they have a legal interest in the matter under litigation, or in the success of
either of the parties, or an interest against both, or that he is so situated as to be
adversely affected by the distribution or other disposition of property in the custody of
the court of an officer thereof;
2. That this intervention will not, in the least, unduly delay in this proceeding or prejudice
the rights of the original parties in the case;
3. That the intervenors rights can be fully protected in this proceeding rather than by
filing a separate proceeding.
WHEREFORE, it is respectfully prayed that MR. AND MRS. RENATO ORTIZ, be
allowed to intervene in this action by filing a Complaint in Intervention, a copy of which is
attached to this motion.
Makati City, Philippines, November 10, 2015.
ATTY. _________________
Attorney for Intervenor
PUTIN & ASSOCIATES 2nd Floor, RCBC Plaza,
Ayala Avenue, Makati City
Roll No. 123456 P.T.R. No. 1234567 / Manila / January 10,
2008
IBP No. 123456/ Manila / January 20, 2008

MCLE Compliance No. 123456