This document is a reply filed in a civil case in Quezon City Regional Trial Court Branch 76 between plaintiff Lutgarda Pearl Joy Soriano and defendant Donna Mae Dumaliang regarding collection of a sum of money. The plaintiff admits some allegations in the answer but denies others, specifically denying allegations that payment was made as admitted in a letter by the defendant. The plaintiff prays for a judgement ordering the defendant to pay all monetary claims stated in the complaint plus costs. The reply was served on the defendant's counsel by registered mail due to time constraints and distance.
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Lutgarda Pearl Joy Soriano,: Plaintiff
This document is a reply filed in a civil case in Quezon City Regional Trial Court Branch 76 between plaintiff Lutgarda Pearl Joy Soriano and defendant Donna Mae Dumaliang regarding collection of a sum of money. The plaintiff admits some allegations in the answer but denies others, specifically denying allegations that payment was made as admitted in a letter by the defendant. The plaintiff prays for a judgement ordering the defendant to pay all monetary claims stated in the complaint plus costs. The reply was served on the defendant's counsel by registered mail due to time constraints and distance.
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REPUBLIC OF THE PHILIPPINES
NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT QUEZON CITY BRANCH 76
LUTGARDA PEARL JOY SORIANO,
Plaintiff,
CIVIL CASE NO. Q:12271994
VS., Collection of Sum of Money
DONNA MAE DUMALIANG
Defendant.
x------------------------------------------x
REPLY
COMES NOW, THE PLAINTIFF, through the undersigned
counsel and unto to this Honorable Court, most avers:
1. That the plaintiff ADMITS the allegations in paragraphs 1 and 3
of the Answer
2. That plaintiff specifically deny the allegation in paragraphs
2,4,5,6 of the answer as the truth of the matter is that there was no payment made by the said defendant as per admission in the letter he executed.
WHEREFORE, Plaintiff prays for judgement
1. Ordering the defendant all his monetary claims as stated in her complaint
2. Cost of suit
Other relief and remedies as may be deemed just and equitable
under the premises are likewise prayed for.
Quezon City November 27, 2017
ATTY. KARINA BASSIG
Counsel for Petitioner
Bassig-Soriano Law Offices
Roll of Attorneys No. 12345
PTR NO. 678911, 12/30/16, Manila
IBP NO. 121314, 12/30/16, Manila
MCLE Comp. No. IV-000888, 12/30/16
CC: Atty. Raven Malaca
Counsel for Defendant 123 Pusong Bato Espanya, Manila.
EXPLANATION OF THE SERVICE
Copy of the reply was served to the counsel for the defendant by registered mail due to time contains and distance, and for lack of the undersigned’s staff who can serve the same in person