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-----------------,
Herein represented by her
Attorney-in-fact -----------,
Plaintiff.
Civil Case No. ----
-versus- For: Sum of Money
-------------------------,
Defendant.
x- - - - - - - - - - - - - - - - - - x
REPLY
PLAINTIFF, herein represented by her Attorney-in-fact, ---, thru the
undersigned Counsel, unto this Honorable Court, most respectfully submits
this Reply to Defendant’s Answer with Counterclaim, thus avers that:
1. Defendant, in paragraphs 3(d), 8(a), 13(a), 17(a) and 20 of her
Answer with Counterclaim, alleged that- “…no interest has ever
accrued in favor of the plaintiff under the second, third, and final
promissory notes”.
It is noteworthy to point out that ------------------. Thus,
defendant’s assertion that no interest has ever accrued in favor of the
plaintiff has no basis.
2. Defendant, in paragraphs 4 and 25 of her Answer with Counterclaim,
alleged that- “It ---------------.”
The truth is that since year February, 2013, plaintiff has already
repeatedly reminded -------------.
3. Defendant, in paragraph 25(a) of her Answer -------------.”
The truth is that th----------.
4. Defendant, in paragraph 25(b) of her Answer with Counterclaim,
alleged that- “---------.”
7. Defendant-debtor has, as of this date, still has not paid herein plaintiff
a single centavo and defaulted in the payment of an aggregate
amount ----------, causing the plaintiff severe damage and prejudice
and loss of her hard-earned money;