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SUPREME COURT
MANILA CITY
FLORENCE RENEE BACAY,
Plaintif,
- versus
JEANNE ESPOLONG
Damages
and
JOHN ROBERT SAM JUAN,
Defendants
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MEMORANDUM
COME NOW DEFENDANT, JOHN ROBERT SAM JUAN, through the
undersigned counsel unto this Honorable Supreme Court most respectfully
submit and present this memorandum in the above title case and aver that:
THE PARTIES
1. Plaintiff Florence Renee Bacay of legal age, single and residing on 20
Ricardo Street Carmel 1 Subdivision, Quezon City where she may be served
with legal processes and notices issued by this Honorable Court;
2. Defendant Jeanne Espolong of legal age, single (to be supplied), where she
may be served with legal processes and notices issued by this Honorable
Court;
3. Co-defendant John Robert Sam Juan of legal age and residing 8 Eisenhower
Street, San Juan, Greenhills, Metro Manila.
I. PROCEDURAL BACKGROUND
1. On Dec. 3, 2013 herein Plaintiff filed a complaint for specific performance
and damages against defendants for failure to pay the amount of the lease
agreement ;
2. On Dec. 18 ,2013 an Answer was filed by the defendants ;