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Republic of the Philippines

REGIONAL TRIAL COURT


THIRD JUDICIAL REGION
Branch --City of ---------------------------------,
Herein represented by her
Attorney-in-fact -----------,
Plaintiff.
Civil Case No. ---For: Sum of Money

-versus-------------------------,
Defendant.
x- - - - - - - - - - - - - - - - - - x

REPLY
PLAINTIFF, herein represented by her Attorney-in-fact, ---, thru the
undersigned Counsel, unto this Honorable Court, most respectfully submits
this Reply to Defendants Answer with Counterclaim, thus avers that:
1 Defendant, in paragraphs 3(d), 8(a), 13(a), 17(a) and 20 of her
Answer with Counterclaim, alleged that- no interest has ever
accrued in favor of the plaintiff under the second, third, and final
promissory notes.
It is noteworthy to point out that ------------------. Thus,
defendants assertion that no interest has ever accrued in favor of the
plaintiff has no basis.
2 Defendant, in paragraphs 4 and 25 of her Answer with Counterclaim,
alleged that- It ---------------.
The truth is that since year February, 2013, plaintiff has already
repeatedly reminded -------------.

3 Defendant, in paragraph 25(a) of her Answer -------------.


The truth is that th----------.
4 Defendant, in paragraph 25(b) of her Answer with Counterclaim,
alleged that- ---------.
The truth is that ---------5 Defendants claim for moral damages is baseless. --------.
6 Defendants claim for exemplary damages is likewise unwarranted as
plaintiff only sought judicial intervention ----------- manner.
7 Defendant-debtor has, as of this date, still has not paid herein plaintiff
a single centavo and defaulted in the payment of an aggregate
amount ----------, causing the plaintiff severe damage and prejudice
and loss of her hard-earned money;
WHEREFORE, premises considered, it is hereby respectfully
prayed that the foregoing Reply to Defendants Answer with
Counterclaim be given due credence and consideration and the reliefs
prayed for in the Complaint be granted.
Finally, Plaintiff respectfully prays for such and other reliefs as may
be deemed just and equitable under the premises.
November 2, 2015, Caloocan City Philippines.
Counsel for the Plaintiff