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IN THE COURT OF THE ADDL.

SENIOR CIVIL JUDGE, ONGOLE


O.S.No.188/2016
Between:
Neelisetty Surya Kumari@ Venkata Surya Kumari Plaintiff

And

Kurapati Srinivasa Raju Defendant


CHIEF EXAMINATION AFFIDAVIT FILED ON BEHALF OF THE
PLAINTIFF (PW-1) U/Or 18 R 4 & Sec.139 C.P.C

I, Neelisetty Surya Kumari @ Venkata Surya Kumari W/o.Subba Rao,


aged about 51 years, Hindu, resident of S.N.Padu Village and Mandal,
Prakasam District, do hereby solemnly affirm and sincerely state as
follows:-
1) I am the deponent herein and plaintiff in the main suit, and I am well
acquainted with the facts. I filed the above suit for recovery of an amount of
Rs.13,01,558/- and for subsequent interest at the rate of 24% per annum
from the date of the suit till the date realization from the defendant.
2) I submit that on 24/05/2013 the defendant borrowed an amount of
Rs.1,83,000/- from me for his business necessities, agreeing to repay the
same together with yearly compoundable interest at the rate of 24% (Rs.2/-)
p.a., per hundred either to me or to my order on demand. In evidencing the
same the defendant executed a promissory note for an amount of
Rs.1,83,000/- in my favour on the same date with his own handwriting in
the presence of attesters at S.N.Padu (V) & (M), Prakasam District.
3). Again that on 24/05/2013 the defendant borrowed an amount of
Rs.1,77,500/- from me for his business necessities, agreeing to repay the
same together with yearly compoundable interest at the rate of 24% (Rs.2/-)
p.a., per hundred either to me or to my order on demand. In evidencing the
same the defendant executed a promissory note for an amount of
Rs.1,77,500/- in my favour on the same date with his own handwriting in
the presence of attesters at S.N.Padu (V) & (M), Prakasam District.
4). Again that on 25/02/2015 the defendant borrowed an amount of
Rs.5,36,000/- from me for his business necessities, agreeing to repay the
same together with yearly compoundable interest at the rate of 24% (Rs.2/-)
p.a., per hundred either to me or to my order on demand. In evidencing the

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same the defendant executed a promissory note for an amount of
Rs.5,36,000/- in my favour on the same date with his own handwriting in
the presence of attesters at S.N.Padu (V) & (M), Prakasam District.
5). Later, I demanded the defendant to repay the borrowed amount but
the defendant has been postponing the same or some pretext or the other.
Later I got issued a registered legal notice dt.23-04-2015 to the defendant
demanding him to repay the borrowed amount through my counsel and on
25-04-2015 the defendant received the same, and the defendant gave reply
notice, dt.29-04-2015 to my counsel with false allegations. The defendant
failed to pay the promissory note amounts together with interest, therefore I
am constrained to file this suit for recovery of amount
6) I further submit that the defendant filed the written statement on his
behalf of and he admitted borrowing and the execution of promissory notes
amounts.
The following documents may be marked as exhibits on my behalf.
1. Original Promissory note dt.24/05/2013, for Rs.1,83,000/-.
2. Original Promissory note dt.24/05/2013, for Rs.1,77,500/-.
3. Original Promissory note dt.25/02/2015, for Rs.5,36,000/-.
4. Office copy of Legal Notice, dt.23-04-2015
5. Post Receipt, dt.23-04-2015 bearing No.RN612683855IN.
6. Acknowledgement, dt.25-04-2015,
7. Reply Notice, dt.29-04-2015 issued by Defendant.

Hence I prays that the Honble court may be pleased to pass a


decree and judgment in my favor and against the defendant for an
amount of Rs.13,01,558/- and subsequent interest at 24% p.a from the
date of suit till the realization and costs of the suit, in the interest of
justice.

DEPONENT
Solemnly affirmed and signed before me the contents of the affidavit is
read over and explained in Telugu to the deponent and admitted her to
be correct on this the 14th day of July, 2017.
Advocate, Ongole.

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V.V.P.K
For:-Plaintif

IN THE COURT OF THE ADDL.


SENIOR CIVIL JUDGE :: ONGOLE

O.S.No.188/2016

CHIEF EXAMINTION AFFIDAVIT


FILED ON BEHALF OF THE
PLAINTIFF (PW-1) UNDER ORDER
18 R 4 & 139 C.P.C

FILED BY:-
Sri.V.V.PAVAN KUMAR
ADVOCATE, ONGOLE.