REPUBLIC OF THE PHILIPPINES
REGIONAL TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
BRANCH _______, MANILA
FIRST AFFAIRS, INC.,
Plaintiff,
– versus – CIVIL CASE NO. 12345
FIVE CLASS PRODUCTS
COMPANY, INC., ET AL.,
Defendants.
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R E P L Y
COMES NOW plaintiff, by its undersigned attorneys, and by way of reply to defendants’ Answer, to this Honorable Court, respectfully states:
I
Defendant partner AAA did not negotiate with plaintiff company in June, 2008 but defendants BBB and/or the late CCC who tried to negotiate from time to time with plaintiff company;
II
Plaintiff did not agree verbally or in writing to accept the mortgaged properties of defendant partner BBB as full payment of the principal obligation contained in the promissory note subject matter of the complaint;
III
Plaintiff is not willing to accept the mortgaged propertied of defendant partner BBB in full satisfaction of the obligation of the defendants in the amount of P35,000.00;
IV
There has been no novation of defendants’ obligation.
WHEREFORE, it is respectfully prayed that judgment be rendered according to the prayer of the complaint.
Manila, February 2011.
EEE, FFF, GGG and HHH
By:
APOLINARIO B. BRAVO
Attorneys for the Plaintiff
(Address)
Copy furnished:
ATTY. BBB
Counsel for the Defendants
(Address)
By: _______________________
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