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XXX, INC.,
Plaintiff,
-versus-
JUDICIAL AFFIDAVIT
I, AAA, of legal age, married, Filipino, presently residing at
________ Marikina City and working as a computer programmer in
KKK Corp. in Quezon City, have been sworn to in accordance with
law, in response to the questions propounded by ATTY. LLL of MMM
LAW OFFICE, with office address at ________ Diliman, Quezon City,
during the examination conducted on 22 February 2013 at the
aforementioned office, cognizant that I may face criminal liability for
false testimony or perjury, hereby depose and state that:
OFFER OF TESTIMONY: The testimony of defendant AAA is being
offered to prove that he is not liable for the full amount being claimed
by the plaintiff since was not adequately informed of the terms and
conditions of his credit card agreement with XXX INC for the two (2)
credit cards, particularly with respect to the imposition of penalties
and surcharges. He will also testify as to his willingness to pay his
credit card obligations, but not the grossly unconscionable interest
rates and penalty charges being imposed by the plaintiff and such
other matters in support of his defense.
1. Question: Are you the same AAA who is a defendant in this case
for Collection of Sum of Money under Civil Case No. 00000
pending before the Regional Trial Court, Makati City, Branch
Answer: Opo, Maam.
2. Question: How did this case come about?
11. Question: How many copies of the application form did you sign
up and sign?
Answer: Just one copy, Maam.
12. Question: After you submitted the application form to the BDO
agent, what did the agent do, if any?
Answer: The agent took the application form and told me again
that the interest rate is 3.5% per month and that I should just follow
up my application by calling their hotline.
13.
Question: For what purpose did you use your credit cards?
Question: How long did you use the two credit cards?