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PEDRO A. SANTOS,
Defendant.
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4. Paragraphs 14, 15, and 16 are specifically denied, the truth being
that the present action is well-founded in fact and in law, filed in
good faith to protect and vindicate the rights of the Plaintiff
violated by the Defendant; therefore, there is no basis whatsoever
1
for the Defendant to recover any damages, attorneys fees nor
expenses of litigation from the Plaintiff;
II
PRAYER
By:
2
Copy furnished, in accordance with
Section 11, Rule 13 of the Revised
Rules of Court, by registered mail,
due to shortage of messengerial
services, to: