Memorandum For Defendant
Memorandum For Defendant
Memorandum For Defendant
Andrew Epal,
Plaintiff,
CIVIL CASE No. 16-74487
- versus - For: COLLECTION OF
SUMS OF
MONEY AND DAMAGES
Gloc Nine,
Defendant.
X--------------X
MEMORANDUM
1. PRELIMINARY STATEMENT
8, 2012;
1.3 That the defendant filed his answer on January 18, 2012, ten
days (10) after he received the said complaint and that his
answer is timely filed within this honorable court and within the
attorney’s fees.
2. THE PARTIES
Commission .
2.3
3.1 That the collection subject of the complaint is that of plaintiff and
under the Notarial Register of Atty. Diok No , Doc. No. 5350, Page
4.3 In the instant case, the plaintiff’s contention that he was not paid
by herein defendantis of no moment considering the fact that it
was based solely on the testimony of the said plaintiff and not on
any other independent evidence. Hence, having failed to adduce
sufficient rebuttal evidence, plaintiff is bound by the contents of
the receipt it issued to herein defendant Gloc Nine . The subject
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5. PRAYER
WHEREFORE, premises considered, it is most respectfully
Other reliefs just and equitable under the premises are likewise
prayed for.
By:
Jethro Villaruel
IBP No. 19185/Sep. 7, 2014/ Quezon City
PTR No. 23632/ March. 2, 2014/Quezon City
Attorney’s Roll No. 767463
MCLE COMPLIANCE NO. IV-176565/03/20/2011
VERIFICATION
I, Gloc Ninel, Filipino, of legal age, a gun shop owner and a
resident of Brgy. San Agustin Iloilo City.
Gloc Nine
Defendant
EXPLANATION
Due to the distance, copy of this Memorandum is served upon
the Office of the Solicitor General though registered mail under the
Registry Receipt hereto attached.
(SGD)
Jethro Villaruel
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