Answer to the Complaint Sample

REPUBLIC OF THE PHILIPPINES METROPOLITAN TRIAL COURT City of Manila Branch 1 MICHAEL BADIRRI, Plaintiff, -versusEDIL Defendant. x--------------------------------------------x ANSWER COMES NOW, the defendant, through the undersigned counsel and unto this Honorable Court, most respectfully avers: That he ADMITS the contents of paragraph 2 only insofar as his personal circumstances are concerned; That he ADMITS his obligation of paying the monthly installments cited in paragraph 3 of the complaint, but DENY the rest of the allegations therein as said defendants obligation to plaintiff is not for the exercise of a right to repurchase but for the amortization of a loan that he acquired from the plaintiff at an interest of 12% per annum; That defendant is without knowledge or information sufficient to form a belief as to the veracity of the averments in paragraph 4 of the complaint; That defendant does not, at the moment, have all the records of payments he made to plaintiff, so that he also does not have information sufficient to form a belief as the truth of the allegations in paragraph 5 of the complaint and, therefore, DENY them. WHEREFORE, the defendant respectfully prays that the complaint be dismissed with costs against the plaintiff. Other relief and remedies as may be deemed just and equitable under the premises are likewise prayed for. City of Manila, September 27, 2012. GACUTAN AND SALAZAR LAW OFFICE Counsel for the Defendant Suite 258 The Tower Malate, Manila By: ARVIN GACUTAN CIVIL CASE NO. 12345 FRANCISCO,

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Roll No. 98765 IBP No, 12345/1-3-2012/Manila PTR No. 34567/1-3-2012/Manila Copy ATTY. FRETTI Counsel for the Unit 1234 Laurel Sampaloc, EXPLANATION Copy of the foregoing ANSWER was served to plaintiffs counsel by registered mail due to time and distance constraints and for lack of the undersigneds staff who can serve the same in person. ARVIN GACUTAN furnished: LAUREL Plaintiff Building Manila