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COMPLAINT WITH PRAYER FOR PRELIMINARY ATTACHMENT

(Caption and Title)

COMPLAINT

Plaintiff thru counsel, and unto this Honorable Court, respectfully avers that:

1. Both the plaintiff and the defendant are of age and residents of
_______________________;

2. (State facts constituting an action for the recovery of money on a cause of action
arising upon a contract, etc.)

3. Defendant is about to remove or dispose of his property, with intent to defraud his
creditors;

4. The amount due to the plaintiff is as much as the sum for which an order of
attachment is sought to be granted, above all legal counterclaims on the part of the defendant;

5. Plaintiff is willing to put up a bond for the issuance of a preliminary attachment in


an amount to be fixed by the court, not exceeding the sum of ______________ PESOS equal to
the amount of the plaintiffs claim, upon the condition that the plaintiff will pay the costs that may
be adjudged to the defendant and all damages which he may sustain by reason of the attachment,
if this Court so adjudge that the applicant was not entitled thereto.

WHEREFORE, it is respectfully prayed that:

1. Pending the hearing of this case, a writ of preliminary attachment be issued


against the property of the defendant to serve as security for the satisfaction of any judgment that
may be recovered herein; and

2. After due hearing on the principal cause of this action, judgment be rendered
against the defendant for the sum of ___________ PESOS with interest at the stipulated rate of
_____ % from _____________, plus costs of this suit.

Other reliefs just and equitable are likewise prayed for.

(Venue, date, signature)

(Verification and Certification of Non-Forum Shopping)

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