Heloooooooooooooooooooooo
Heloooooooooooooooooooooo
Heloooooooooooooooooooooo
x---------------------------------------------x
COMPLAINT
4. That the defendant has failed and refused to pay the said
indebtedness on due date, with corresponding interest and penalty thereon to
the herein plaintiff, despite repeated requests and demands.
5. That the plaintiff served several demand letters to the defendant.
Attached is the last demand letter executed on August 1, 2019 by the plaintiff
as Annex “B” and made as an integral part hereof;
6. That the defendant shall pay for the attorney’s fees and expenses
of litigation in the amount of P100,000.00 and a fee of P10,000 for every
appearance in court, and to pay the cost of this suit;
7. That Plaintiff has a valid and sufficient cause of action against the
herein defendant regarding the collection of sum of money which is already due
and demandable;
9. That the defendant does not have sufficient security for the claim
sought for the plaintiff against him;
10. That the plaintiff is willing to put up a bond for the issuance of a
preliminary attachment in an amount to be fixed by the court;
PRAYER
Plaintiff likewise prays for such other and further relief or reliefs as this
Honorable Court may deem just and equitable under the premises.
I, PROF E. SSOR, of legal age, single, Filipino and a resident of #01 Unang
St., First Village, Baguio City, under oath depose and state that:
I further certify under oath that I have not commenced any similar action
before the Supreme Court, Court of Appeals, or before any court, tribunal or
agency concerned; and should I learn of any similar cause of action filed before
any of the aforesaid bodies, I undertake to notify this Honorable Court within
five (5) days from notice.
In witness whereof, I have hereunto set my hand this 22nd day of August,
2019 at Baguio City.
PROF E. SSOR
Affiant
STEVE JACK MA
Notary Public for and in the City of Baguio
Until December 31, 2019
Contact No. +63916 201 9144
Roll No. 111111
Doc. No. 01; TIN No. 111-111-111
Page No. 02; IBP No. 99999 – Baguio City – 02/02/2019
PTR No. 99999 -Baguio City – 08/08/2018
Book No. XX; MCLE Certificate of Compliance No. 0000001
Series of 2019. Upper Session Rd., Baguio City