Subject Matter of This Action

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COMPLAINT

PLAINTIFF, by counsel, respectfully states that:

1. Plaintiff and defendants are all of legal age; plaintiff resides at at 3


Rose st. Tondo Manila while defendants reside at at 4 Rose st. Tondo
Manila and at 5 Rose st. Tondo Manila, respectively, where they may
be served with pertinent notices;
2. On 1 June 2007, plaintiff found a Gold Rolex Oyster watch, without
knowing who its true owner is. The watch is now in plaintiff’s
possession. On or about 5 June 1999, defendants made similar
representations to plaintiff as to ownership of the watch.
3. Plaintiff, who claims no interest in the watch, cannot determine the
conflicting claims of defendants and thus seeks to compel defendants
to interplead and litigate their several claims between themselves.

WHEREFORE, it is respectfully prayed that this Honorable Court issue


an order directing defendants to interplead with one another to determine
their respective rights and claims and to allow plaintiff to recover his
expenses for safekeeping and the costs of this suit, as first lien upon the
subject matter of this action.

City of Manila 7 May 2019.

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