PETITIONER, through the undersigned counsel, to this
Honorable Court, respectfully offers the foregoing exhibits:
1. Exhibit A: The Report of Marriage Contracted
Abroad between the parties to this case. . Purpose: Offered as evidence in itself, to prove that the petitioner and respondent are married to each other and as part of the testimony of the petitioner and her witnesses.
2. Exhibit B: The Notice of Appearance from the
Office of the Solicitor General. Purpose: Offered to prove that the State was duly notified of the present action and as evidence in itself.
3. Exhibit C: The Report and Recommendation of
dated July 3, 2013 by Assoc. Provincial Prosecutor xxxxxxxxxxxxxxxxxxxxxxxxxx.
Purpose: Offered as evidence in itself and as part
of the testimony of the petitioner. Likewise offered to prove that no collusion exist between the parties in the filing of this petition and that the evidence presented were not fabricated or suppressed.
4. Exhibit D: The Special Power of Attorney
executed by the petitioner in favor of her brother, xxxxxxxxxxxxxxxxxxxxxxxxxx, to appear for and in her behalf during the proceedings of the above-captioned case.
5. Exhibit E: The Judicial Affidavit of the
petitioner, xxxxxxxxxxxxxxxxxxxxxxxxxx. Exhibit E-1: Name and signature of xxxxxxxxxxxxxxxxxxxxxxxxxx.
Purpose: Offered as petitioners direct testimony.
6. Exhibit F: The Judicial Affidavit of xxxxxxxxxxxxxxxxxxxxxxxxxx. Exhibit F-1: Name and signature of xxxxxxxxxxxxxxxxxxxxxxxxxx.
Purpose: Offered as direct testimony of
xxxxxxxxxxxxxxxxxxxxxxxxxx and to corroborate the testimony of the petitioner.
7. Exhibit G: The Certificate of Marriage between
respondent and a certain xxxxxxxxxxxxxxxxxxxxxxxxxx.
Purpose: Offered as evidence in itself and to
prove that respondent contracted a second marriage during the subsistence of his marriage to the petitioner.
8. Exhibit H: The Certificate of Live Birth of
xxxxxxxxxxxxxxxxxxxxxxxxxx.
Exhibit I: The Certificate of Live Birth of
xxxxxxxxxxxxxxxxxxxxxxxxxx.
Purpose: Offered as evidence in itself and to
prove that respondent has two children in his second marriage.
9. Exhibit J: The Judicial Affidavit of Dra.
xxxxxxxxxxxxxxxxxxxxxxxxxx. Exhibit J-1: Name and signature of Dra. xxxxxxxxxxxxxxxxxxxxxxxxxx.
Purpose: Offered as the said witness direct
testimony and to corroborate the testimony of the petitioner.
10. Exhibit K: The Psychiatric Evaluation Report
executed by Dr. xxxxxxxxxxxxxxxxxxxxxxxxxx. Exhibit K-1: Name and signature of Dra. xxxxxxxxxxxxxxxxxxxxxxxxxx.
Purpose: Offered as evidence in itself and as part
of the testimony of the Petitioner and Dra. xxxxxxxxxxxxxxxxxxxxxxxxxx, the expert witness. It is also offered to prove that Dr. xxxxxxxxxxxxxxxxxxxxxxxxxx conducted a psychiatric evaluation upon the petitioner, who was thoroughly examined and evaluated by the psychiatrist. It is further offered to prove that indeed respondents behavior and actuations show psychological incapacity already present before, during and after the marriage which is of a serious, permanent and incurable nature rendering him unfit and incapable to perform the essential obligations of marriage. It is also offered to prove that the recommendations of the expert witness (in the field of Psychiatry) Dra. xxxxxxxxxxxxxxxxxxxxxxxxxx is that it is best for both parties that their marriage be declared null and void. Likewise offered to prove the authenticity and due execution of the Psychiatric Evaluation Report.
WHEREFORE, it is prayed to this Honorable Court that
the above-mentioned exhibits be admitted for the purpose to which they are being offered.
Other just and equitable reliefs are likewise prayed for.
Brief for National Assn of Reversionary Property Owners, National Cattlemen's Beef Assn, and Public Lands Council as Amici Curiae in Support of Appellees and Urging Affirmance, Caquelin v. United States. No. 16-1663 (Dec. 28, 2016)-NCBA-PLC Amicus Brief