1a.-sum-of-money-with-writ-of-preliminary-attachment-1.doc

REPUBLIC OF THE PHILIPPINES REGIONAL TRIAL COURT OF MANILA National Capital Judicial Region Banc! """"# Iloilo Cit$

Ale%ande Si&on# Plainti))#

Ci'il Ca&e No( """"" Fo* Collection o) Su+ o)   Mone$ ,it! Pa$e o) ,it )o t!e i&&uance o) Peli+ina$ Attac!+ent

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Juan Ja+eo# .e)endant( %------------------------------------------% COMPLAINT PLAINTIFF# through counsel, most respectfully avers:

(1. (1.)

That That pla plaint intiff, iff, Alex lexand ander Siso Sison n is is a Fil Filipi ipino citi itien en, of  of  legal age, single and a resident of 111 !i"ertad St. Sampaloc #anila, $hereas, defendant %uan %amero is li&e$ise a Filipino, of legal age, single, and residing at ''' %uan !una St., Tondo #anila, at $hich address the  party herein may "e served $ith summons and other  court processes

('.)

That on %a %anuary , '* '**+, def defendant "or "orro$ed fro from  plaintiff the amount of one million pesos (hp. 1,***,***.**) , $hich inde"tedness is due and paya"le on or "efore %anuary , '**-, $ith an interest at the rat rate of 1' 1' per annu annum m $ith $ithiin one one (1) (1) year ear, in accordance $ith the promissory note executed "y the defendant defendant on the the said date. date. hotostati hotostaticc copy of said said  promissory note is attached and mar&ed as Annex /A0 and made as a integral part hereof

(. (.)

That That the the def defen enda dan nt ha has fail failed ed and refu refuse sed d and and stil stilll fail failss and refuses to pay the said inde"tedness on due date, $ith $ith corre corresp spon ondi ding ng inte interes restt ther thereo eon n to the the here herein in  plaintiff, despite despite repeated reuests and demands. demands.

(2.)

That the plaintiff served several demands to the defendant, attached is the last demand letter executed on %uly *1, '**- "y the plaintiff as annex /30 and made as an integral part hereof

(4. (4.)

That That the the de defend fendan antt sha shalll pay pay for for the the att attorne orney5 y5ss fee fees an and expenses of litigation in the amount of hp. 64,***.** and a fee of ,*** for every appearance in court, and to pay the cost of this suit

(7.)

That th the pl plaintiff is is $i $illing to to pu put up up a "on "ond fo for the the issuance of a preliminary attachment in an amount to  "e fixed "y the court, not exceeding the sum of one million pesos $hich is the plaintiff5s claim herein

 Allegations for the Issuance Issuance of for Preliminar Preliminaryy Attachment  Attachment 

laintiff further states and alleges: (6.)

That l laintiff ha has a va valid an and su sufficient ca cause of of ac action against the herein defendant regarding the collection of  sum of money $hich is already due and demanda"le

(+.)

8efendant ha has re removed or or di disposed of of or or is is a" a"out to to remo remove ve or disp dispos osee of her her prop propert erty y, $ith $ith inte intent nt to defraud her creditors there"y rendering nugatory and ineffective $hatever money 9udgment this honora"le court may render in the a"ove entitled case That That the defe defend ndan antt doe doess not not hav havee su sufficie cient sec securit urity y for  for  the claim sought for the plaintiff against him

(-. (-.)

(1*.)

That the the pl plaintiff is $i $illing to pu put up a "o "ond fo for the the issuance of a preliminary attachment in an amount to  "e fixed "y the court, not exceeding the sum of one million pesos $hich is the plaintiff5s claim herein

PRA/ER  0HEREFORE, it is most respectfully prayed of this onora"le ;ourt that pending hearing of this case a $rit of preliminary attachment "e issued against the  property of the defendant to serve as security for the

satisf satisfact action ion of any 9udgme 9udgment nt that that may "e recove recovered red herein and that after due hearing on the principal pr incipal cause of this this acti action on,, 9udg 9udgme ment nt "e rend render ered ed agai agains nstt the the defendant for the sum of the follo$ing: (1.) ;ompliance o1B*****77 8ate @ssued: %anuary , '**7 8oc. o( 2"  age o3 3oo&. o( I Series of '**8ate and Time otaried: CCCCCCCCCC 

/A>D A0

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