Republic of the Philippines

REGIONAL TRIAL COURT

11TH Judicial Region

Branch 17

Davao City

LEON TROTSKY

Intervenor, CIVIL CASE No. 128-9456

For: INTERVENTION

VS.

DEREK RAMSY

Plaintiff
-x------------------------------------------- x

COMLAINT-IN-INTERVENTION

INTERVENOR, by counsel, unto this Honorable Court respectfully

states and prays that:

1. Intervenor, a Russian but naturalized Filipino citizen, of legal age, married to

Jessica Sanchez, a Filipino citizen and a resident of Trotsky resort, Boracay
Island, Philippines.

2. Herein Intervenor is the true owner of the property which is the subject of
controversy in Civil Case No. 128-9456, embraced in the alleged new
Transfer Certificate of Title No. 11919, originally under TCT No. 12345,
(hereto attached as Annex “A-1”) with an area of five thousand square
meters (5,000 sq m) located at Brgy. San Isidro, Babak Pulong Harding
Lungsod ng Samal, Philippines.

3. Said property in question, was acquired by the Intervenor from Kobe Bryant
on June 7, 2005 in consideration of P1,500,000.00 as stated in the Deed of
Sale registered under the name of Kobe Bryant and Jessica Sanchez,
recorded in the Registry of Deeds in the Province of Davao del Norte.
(copy attached as Annex” A-2”)

4. The litigants in this case, (plaintiff) as claimant and (defendant) who is in

actual used and possession of the property in question, have no legal
standing of their claims on the basis that all transactions and performances
subsequent to the transaction executed between herein Intervenor and Mr.
Kobe Bryant in relation to the property in question described in the original
title TCT 12345 and in TCT 11919 is presumed to be void considering that
said property was already sold to Intervenor and now is the subject of this
complaint.
 5. The Intervenor deeply affected of the fraudulent transactions initiated by the
irresponsible vendor (Kobe Bryant) of the questioned property, which is the
subject matter in this case, that caused him to initiate legal remedy for the
relief and recovery of damages inflicted to his person, and bring the matter
to this honorable court in a way of intervention.

WHERFORE, it is prayed:

1. That all transactions and performances executed by the litigants in relation to

the property-in-question, including related documents in their possession shall
be declared void.

2. That the litigants be ordered by this Honorable Court to voluntarily turn-over

the questioned property to the rightful owner who is the Intervenor in this case.

3. That if voluntary turn-over of the property or waiver of the claim by both

plaintiff and defendants is not possible, order be made against the litigants to
pay for the damages and other litigation expenses plus attorney’s fees in favor
of the Intervenor.

4. Further it is prayed that Intervenor be granted such relief found to be consistent

with law and equity.

Signed this 4th day of March 2013 in Davao City, Philippines.

LEON TROTSKY

Intervenor

Assisting Counsels:

LEONARDO P. CATARAJA

Davao City

GINA VILLE I. VILCHEZ

Davao City

CHARMAINE D. BARCELONA

Davao City

CHIRA DEE T. SINET

Davao City
 Republic of the Philippines

REGIONAL TRIAL COURT

11TH Judicial Region

Branch 99

Panabo City

DEREK RAMSY

Plaintiff, CIVIL CASE No. ._128-9456

VS. For: RECOVERY OF POSSESION

DAMAGES AND ATTORNEY’S FEE

SPOUSES PETER AND DEBORAH TOSH

Defendant

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

MOTION FOR INTERVENTION

COMES NOW, the Intervenor, LEON TROTSKY, by this undersigned counsel, and
to this Honorable Court respectfully prays that he be permitted to file a Complaint in
Intervention in the above entitled case, for the following reasons:

1. That he has 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 the adversely affected by the distribution or other
disposition of the property which is the subject of the controversy.

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 intervenor’s right can be fully protected in this proceeding rather than by filing a separate
proceeding.

WHEREOF, it is respectfully prayed that LEON TROTSKY be allowed to intervene as party plaintiff (or
defendant) and the attached complaint be admitted and served on the defendant (or the answer be admitted and
served to the plaintiff).

Davao City, Philippines, March 4,2013.

LEON TROTSKY

Intervenor

LEONARDO P CATARAJA

Attorney for Intervnor

Assisting Counsels:

GINA VILLE I. VILCHEZ

CHARMAINE D. BARCELONA

CHIRA DEE T. SINET

Davao City
 NOTICE OF HEARING

TO: ATTY. PETE BAYANI CAMPOREDONDO

Counsel for the Plaintiff

Sir: Please take notice that on Tuesday, March 5, 2013 at 7;30 in the evening or as soon
thereafter as counsel may be heard, the undersigned attorney will ask the Regional Trial Court of
Panabo City (Brach 99) that the foregoing Complaint- in Intervention be granted.

LEONARDO P CATARAJA

Attorney for the Intervenor

Copy of this Complaint – in Intervention with notice of hearing was sent by registered
mail on March 4, 2013 to Atty PETE BAYANI CAMPOREDONDO at Door 69, Building 54,
Island Garden City of Samal, personal service being impractical due to distance.

LEONARDO P CATARAJA