Plaintiff Marinka Peschmann's Reply To Defendants Opposition To Terminate Neutral With Glasser Questionnaire Judge Richard Lanzillo Judge Susan P Baxter
Plaintiff, through the undersigned counsel, to this Honorable Court, respectfully alleges that:
1. Plaintiff is of legal age, (single or married), and a resident of ______________________ while defendant is of legal age, (single or married), and a resident of _____________________ where (he/she) may be served with summons;
2. Plaintiff is the owner of a building in _____________________, which was leased to the defendant on _______________ to ________________ at a monthly rental of P__________________;
3. The defendant failed to pay the monthly rentals for __ months, and despite written and oral demands to vacate, defendant failed to pay said rentals in arrears in the amount of P______________________;
4. Due to the defendants adamant refusal to vacate the leased premises, plaintiff was constrained to initiate the suit and to incur expenses in the amount of P_____________________, aside from costs of suit;
5. Prior to the filing of this complaint, this dispute was brought to the Lupong Tagapamayapa of Barangay __________________, where the leased CIVIL CASE NO. _______________
For:
2 premises is located, but no settlement was arrived at, as evidenced by the Certification to File Action issued by the Barangay Chairman, a copy of which is hereto attached as Annex A hereof.
WHEREFORE, it is respectfully prayed that, after due hearing, judgment be rendered, ordering the defendant, and all persons acting under him, to pay the rentals in arrears in the amount of P______________ with legal interest, to vacate the aforementioned leased premises, and to pay the amount of P_____________ as and for attorneys fees, plus costs of suit.
Plaintiff prays for such other and further relief as may be just and equitable under the premises.
_______________________________ Counsel for the Plaintiff (Address) (Roll No.; IBP No.; PTR No., date & place issued)
VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING
I, ______________________, of legal age and a resident of ________________, after having been duly sworn, hereby depose and state:
1. That I am the plaintiff in the above-entitled case; that I have caused the foregoing complaint to be prepared; that I have read the same, and the allegations therein contained are true of my own personal knowledge or based on authentic documents.
2. That I further certify that I have not heretofore commenced any action or filed any claim involving the same issues in any court, tribunal or quasi- judicial agency, and to the best of my knowledge, no such action or claim is pending therein, and if I should thereafter learn that the same or similar
3 action or claim has been filed or is pending, I will report that fact within five(5) days therefrom to this Honorable Court.
SUBSCRIBED AND SWORN to before me, in the City of _______________, this ____ day of _____________, 2007, the affiant exhibiting to me his Community Tax Certificate No. _______________ issued at _______________________ on _________________ and Tax Identification No. _________________.
NOTARY PUBLIC
Doc. No. _____; Page No. _____; Book No. ____; Series of 2007.
Plaintiff Marinka Peschmann's Reply To Defendants Opposition To Terminate Neutral With Glasser Questionnaire Judge Richard Lanzillo Judge Susan P Baxter