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 Defendant’s 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, defendant’s 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 Defendant’s claim for moral damages is baseless. --------. 6 Defendant’s 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 Defendant’s 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
