Republic of the Philippines

REGIONAL TRIAL COURT OF CEBU

7th Judicial Region
BRANCH ___
Cebu City

_________________________,
Plaintiff,

- versus - Civil Case No. ___________

For: Collection for Sum of
Money
_________________________,
Defendant.
x -----------------------------------------------/

WRITTEN INTERROGATORIES

TO: _____________, Defendant

FROM: __________________, Plaintiff

Instructions

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

requested to answer within fifteen (15) days the following
interrogatories.

a) In accordance with Rule 25 Section 2, your response shall

be answered fully in writing and shall be signed and sworn
by you.

b) Also in accordance with Rule 25 Section 2, you shall file and

serve a copy of the answers within fifteen (15) days after
service thereof, unless the court on motion and for good
cause shown, extends or shortens the time.

c) 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.

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Definitions

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.

c) Where knowledge of information or possession of a party is

requested, such request includes knowledge of the party’s
agents, representatives and, unless privileged, his attorneys.
When answer is made by a public or private corporation or a
partnership or association, state the name, address, and title of
the person supplying the information, and making the affidavit,
and the source of his information.

d) The pronoun “you” refers to the party whom these

Interrogatories are addressed, and the persons mentioned in
clause (c).

Interrogatories

1. Please state the name, law firm address and your relationship
with the person who helped you in the preparation of this
document.

2. Since you admitted paragraph 1 of our complaint, how did you

meet or come to know the plaintiff?

3. Do you know any business that the plaintiff owns?

4. Did the plaintiff deliver any amount of money to you?

5. Did you execute a Promissory Note dated _________?

6. If yes, did you execute such as an evidence of a loan obligation

to the plaintiff?

7. xxx

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 8. xxx

9. xxx

10. Did you receive a demand letter from the plaintiff dated
__________ asking you to pay in full the amount of
_________?

The written interrogatories were served upon the defendant after

the filing of her answer dated _____________.

Cebu City, Philippines, __ of ____________, _____.

(Signature)
ATTY. ______________________
Counsel for the Plaintiff
Roll of Attorneys No. _______
IBP No. _____; _____; _____
PTR No. _____; _____; _____
MCLE Compliance No. _____
(Office Address)
(Telephone Number)
(Email Address)

Copy Furnished through personal service:

ATTY. ________________ Received by: ___________

Counsel for the Defendant Date : ___________
(Office Address)

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