Republic of the Philippines

REGIONAL TRIAL COURT

Seventh Judicial Region
BRANCH _8_
Cebu City

MONA LISA GO,

Plaintiff,
Civil Case No. 14344
-versus- For: Collection of Sum of
Money

LAUREN YOUNG,
Defendant.
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WRITTEN INTERROGATORIES

To: LAUREN YOUNG, Defendant

From: MONA LISA GO, Plaintiff

Instructions:

Pursuant to Rule 25 of the Rules of Court, you are requested to

answer fully in writing and under oath the following interrogatories
within fifteen (15) days after service thereof, unless the court on
motion and for good cause shown extends or shortens the time:

a.) Where the name or identity of a person is requested, please

state the full name, home address, and also business address, if
known.
b.) Unless otherwise indicated, these interrogatories refer to time
place, and circumstances of the occurrence mentioned or
complained of in the pleadings.

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c.) Where knowledge of information in possession of a party is
requested, such request includes knowledge of the party’s
agents, representatives and unless privileged, his attorneys.
d.) The pronoun “you” refers to the party to whom these
interrogatories are addressed and the person mentioned in
clause (c).
e.) If in answering these interrogatories, you encounter any
ambiguities in construing a question, instruction, or definition,
set forth the matter deemed ambiguous and the construction
used in writing.

Interrogatories

1. State your full name, current address and status.

2. Are you the same person sued by Mona Lisa Go (Mona Lisa for
brevity) in a collection case docketed as Civil Case No. 14344?

3. According to your answer, you admitted that on January 11,

2018, you borrowed a certain amount of money from Mona Lisa
and as a result thereof, a promissory note was executed. Please
answer the following questions:
3.1 Who executed the Promissory Note?
3.2 How was it executed? Was it handwritten or typewritten?
3.3 Where was it executed?
3.4 When was it executed?
3.5 Were there other persons present when it was executed
other than you and Mona Lisa? If so, who were they?
3.6 Who has the custody of the original copy of the
Promissory Note after its execution?
3.7 Were you given a copy of the said note?

4. In your answer, you further said that the amount of the

promissory note was only P500,000.00 claiming that the five (5)
monthly installments was only P100,000.00 each month. Please
answer the following questions:

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 4.1 How much money did you actually receive from the
Plaintiff at the time of transaction?
4.2 Is the borrowed money given at once or by installment? If
by Installment, when were they given? (If possible, state
the exact dates, if not just the month and the year)
4.3 In what form did Mona Lisa give to you the borrowed
money? Is it by cash or by check?
4.4 Were there other persons present at the time when Mona
Lisa lent to you the borrowed money? If so, who were
they?

5. You further alleged that payment has already been made, if so,
please answer the following questions:
5.1 When did you pay?
5.2 Where did you pay?
5.3 How much did you pay?
5.4 To whom did you give the payment?
5.5 How was payment made? Is it by cash or by check?
5.6 Were there other persons present at the time that you
paid? If so, who were they?

Cebu City, Philippines, March 8, 2019.

ATTY. MARY MAE LIMPANGUG

Counsel for Plaintiff
Cebu City Roll of Attorney No. 53244
PTR No. 2941374, 01/01/2019, Cebu City
IBP No. 112456-Lifetime Member, Cebu Province
MCLE Compliance No. V-9137424
Tel. No. (02) 225-8023
E-Mail Address: marymaelimpangug@gmail.com
EH 501, USC, Pelaez St., Cebu City

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