REPUBLIC
OF THE PHILIPPINES)
CITY OF MANILA )S.S.
AFFIDAVIT
A, of legal age, married and a
resident of the City of Manila, Philippines, after having duly sworn in
accordance with law, hereby deposes and says:
That he is the Plaintiff in the above titled case and
that he has read the foregoing complaint and that the facts therein stated are
true and correct;
That he is the owner of the estate as pro-indiviso owner
of the same with the defendant;
That the defendant is in actual physical possession of
the property in litigation and as such, he is in control of the produce of the
said property pending litigation;
That the produce or income from said property are in
danger of being lost, removed or materially injured unless a receiver be
appointed to guard and preserve the same, and the defendant is not only hostile
to the plaintiff but also shows his demands to exclude said plaintiff from all
the products or proceeds coming from the said property;
That the defendant is hopelessly insolvent for he is
heavily indebted to various persons;
That he is willing and ready to file
a bond in the amount which this Honorable Court may fix in favor of the
defendant against whom this receivership is presented to the effect that he, the
plaintiff will pay to the said defendant all damages which he will sustain by
reason of the appointment of receiver in case the plaintiff shall have procured
such appointment without sufficient cause, and such other bonds which this
Honorable Court may require him to file hereafter, as security for such
damages.
FURTHER AFFIANT SAYETH NAUGHT.
______________________
(Affiant)