Republic of the Philippines

FIRST JUDICIAL REGION

REGIONAL TRIAL COURT
Branch 50
Villasis, Pangasinan

CHARLOTTE B. TAGAMA PAGSOLINGAN,

Plaintiff, CIVIL CASE No.

V-1049

-versus-

PAUL W. PAGSOLINGAN,

Defendant,

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MOTION TO CONDUCT INVESTIGATION TO

DETERMINE WHETHER OR NOT COLLUSION EXISTS
BETWEEN THE PARTIES

1. The original copy of the Summons issued in the

instant case was duly served to the Respondent on November
8. 20211.

2. The Respondent has not filed any answer up to this

date.

3. Pursuant to A.M. No. 02-11-10-SC, “Where no answer

is filed or if the answer does not tender an issue, the court shall order
the public prosecutor to investigate whether collusion exists between
the parties”2.

1
Return of Service dated Nov 8, 2021 executed by Edward S. Mamaril, Process Server.
2
Sec. 8 of A.M. No. 02-11-10-SC, March 4, 2003.

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 PRAYER

WHEREFORE PREMISES CONSIDERED, it is most

respectfully prayed that the Honorable Court issue an order for
the Honorable Public Prosecutor to investigate whether or not
collusion exists between the parties.

Other reliefs just and equitable are likewise prayed for.

Done this 13th day of December 2021 at Quezon City,

Metro Manila for San Carlos City, Pangasinan.

By:

MADRIROSE B. TIJAMO
Counsel for the Petitioner
Roll of Attorneys No. 49213
PTR. No. 1041728/ February 17, 2021/QC
IBP Lifetime Member No. 09284
` MCLE Compliance No. VI-00258865/April 29, 2019
Mobile Nos. 63+ 916 356 3983
Email: atty_swanie@live.com

Copy Furnished:

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The Office of the Solicitor General

134 Amorsolo St. Salcedo Village

Makati City

Paul W. Pagsolingan

Brgy. Amancosiling Norte

Bayambang, Pangasinan

The Office of the Provincial Prosecutor

San Carlos City, Pangasinan

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