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Answer For Collection of Sum of Money With Damages
Answer For Collection of Sum of Money With Damages
ANSWER
1. Paragraphs one (1) and two (2) of the Complaint are admitted;
2. Paragraphs three (3) to five (5) of the Complaint are denied for lack
of knowledge or information sufficient to form a belief as to the
veracity or falsity thereof, the allegations therein being matters
known only to and are within the control only of the plaintiff;
1. On May 25, 2015, the Defendant and the Plaintiff did not see each
other because the former was having a vacation in Baguio City as
evidenced by the photocopy of entry/exit of vehicles monitoring
sheet, attached herein, marked as Annex A, and made an integral
part hereto. Such monitoring sheet is issued by the Gate Security
Department of the Subdivision where the Defendant resides.
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Complaint
2. The Plaintiff never gave the defendant the alleged amount of Three
Hundred Fifty Thousand Pesos (350,000.00); that Defendant did
not sign the alleged promissory note; and that Defendants
signature is forged.
COMPULSARY COUNTERCLAIM
PRAYER
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Complaint
Lipa City, Batangas. December 5, 2015.
By:
TRIVEN P. CASTILLO
Roll of Attorney No. 45969
PTR No. 123456; 01-02-01 / Lipa City
IBP Life Member Roll No. 445789/07-08-01 / Lipa City
MCLE Compliance No. III-897656 / 12-10-01
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Complaint
VERIFICATION and CERTIFICATION OF NON-FORUM
SHOPPING
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Complaint
other tribunal or agency, I undertake to report that fact within five
(5) days therefrom to this Honorable Court
TRIVEN P. CASTILLO
Notary Public
Valid Until December 31, 2015
Roll of Attorney No. 45969
PTR No. 123456; 01-02-01 / Lipa City
IBP Life Member Roll No. 445789/07-08-01 / Lipa City
MCLE Compliance No. III-897656 / 12-10-01
Doc. No.: 49
Page No.: 8
Book No.: II
Series of 2015
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Complaint