Professional Documents
Culture Documents
ANSWER
COMES NOW, the defendant, through the undersigned counsel and unto this Honorable Court,
most respectfully avers:
1. That he ADMITS the contents of paragraphs 1 and 2 only insofar as his personal circumstances
are concerned;
2. That defendant is without knowledge or information sufficient to form a belief as to the veracity
of the averments in paragraphs 4 and 5 of the complaint;
3. That defendant does not, at the moment, have all the records of payments he made to plaintiff,
so that he also does not have information sufficient to form a belief as the truth of the allegations in
paragraphs 5-7 of the complaint and, therefore, DENY them.
4.
WHEREFORE, the defendant respectfully prays that the complaint be dismissed with costs against
the plaintiff.
Other relief and remedies as may be deemed just and equitable under the premises are likewise
prayed for.
By:
DESIREE E. KURIMAO
Roll No. 98765
IBP No, 12345/1-3-2012/Manila
PTR No. 34567/1-3-2012/Manila
Copy furnished:
ATTY. PARK K. TILAOPAO
Counsel for the Plaintiff
Unit 1234 Apple One Building
Cebu City, Philippines
EXPLANATION
Copy of the foregoing ANSWER was served to plaintiffs counsel by registered mail due to time and
distance constraints and for lack of the undersigneds staff who can serve the same in person.
DESIREE E. KURIMAO