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Answer Civil Case 2
Answer Civil Case 2
MICHAEL BADIRRI,
Plaintiff,
-versus-
EDIL FRANCISCO,
Defendant.
x--------------------------------------------x
ANSWER
1.
2.
3.
4.
COMES NOW, the defendant, through the undersigned counsel and unto this Honorable
Court, most respectfully avers:
That he ADMITS the contents of paragraph 2 only insofar as his personal circumstances are
concerned;
That he ADMITS his obligation of paying the monthly installments cited in paragraph 3 of the
complaint, but DENY the rest of the allegations therein as said defendants obligation to plaintiff is
not for the exercise of a right to repurchase but for the amortization of a loan that he acquired from
the plaintiff at an interest of 12% per annum;
That defendant is without knowledge or information sufficient to form a belief as to the
veracity of the averments in paragraph 4 of the complaint;
That defendant does not, at the moment, have all the records of payments he made to
plaintiff, so that he also does not have information sufficient to form a belief as the truth of the
allegations in paragraph 5 of the complaint and, therefore, DENY them.
WHEREFORE, the defendant respectfully prays that the complaint be dismissed with costs
against the plaintiff.
Other relief and remedies as may be deemed just and equitable under the premises are
likewise prayed for.
City of Manila, September 27, 2012.
GACUTAN AND SALAZAR LAW OFFICE
Counsel for the Defendant
Suite 258 The Tower
Malate, Manila
By:
ARVIN GACUTAN
Roll No. 98765
IBP No, 12345/1-3-2012/Manila
PTR No. 34567/1-3-2012/Manila
Copy furnished:
ATTY. FRETTI LAUREL
Counsel for the Plaintiff
EXPLANATION
Copy of the foregoing ANSWER was served to plaintiffs counsel by registered mail due to time
and distance constraints and for lack of the undersigneds staff who can serve the same in person.
ARVIN GACUTAN