The defendant files an answer to the plaintiff's complaint for trespass. The defendant admits the allegations in paragraphs 2, 3 and 4 of the complaint but denies having sufficient records to admit or deny the allegations in paragraphs 6 and 7. The defendant also denies having sufficient information to form a belief about the allegations in paragraph 8. The defendant specifically denies the allegations in paragraphs 9, 10 and 11, claiming the contract allows them to rescind the contract and repossess items without consent or judicial proceedings if payments are not made on time. The defendant requests the complaint be dismissed with costs awarded to the defendant.
The defendant files an answer to the plaintiff's complaint for trespass. The defendant admits the allegations in paragraphs 2, 3 and 4 of the complaint but denies having sufficient records to admit or deny the allegations in paragraphs 6 and 7. The defendant also denies having sufficient information to form a belief about the allegations in paragraph 8. The defendant specifically denies the allegations in paragraphs 9, 10 and 11, claiming the contract allows them to rescind the contract and repossess items without consent or judicial proceedings if payments are not made on time. The defendant requests the complaint be dismissed with costs awarded to the defendant.
The defendant files an answer to the plaintiff's complaint for trespass. The defendant admits the allegations in paragraphs 2, 3 and 4 of the complaint but denies having sufficient records to admit or deny the allegations in paragraphs 6 and 7. The defendant also denies having sufficient information to form a belief about the allegations in paragraph 8. The defendant specifically denies the allegations in paragraphs 9, 10 and 11, claiming the contract allows them to rescind the contract and repossess items without consent or judicial proceedings if payments are not made on time. The defendant requests the complaint be dismissed with costs awarded to the defendant.
The defendant files an answer to the plaintiff's complaint for trespass. The defendant admits the allegations in paragraphs 2, 3 and 4 of the complaint but denies having sufficient records to admit or deny the allegations in paragraphs 6 and 7. The defendant also denies having sufficient information to form a belief about the allegations in paragraph 8. The defendant specifically denies the allegations in paragraphs 9, 10 and 11, claiming the contract allows them to rescind the contract and repossess items without consent or judicial proceedings if payments are not made on time. The defendant requests the complaint be dismissed with costs awarded to the defendant.
COMES NOW, the defendant, through the undersigned counsel and unto this Honorable Court, most respectfully avers:
1. That defendant admits the averments in paragraphs 2,3 and 4 of the complaint;
2. That defendant does not, at the moment, have all the records of payments made by the plaintiff; so that, they do not have sufficient information to form a belief as to the truth of the allegations in paragraphs 6 and 7 of the complaint, therefore, deny them.
3. That defendant, without knowledge to form a belief as to the veracity of the averments in paragraph 8 of the complaint;
4. That defendant denies, specifically each and every material allegations made in paragraphs 9, 10 and 11 of the complaint; and alleges that, according to the contract to sell, in the case where the plaintiff fails to pay within the agreed period stated therein, the defendant may rescind the contract without need of any consent from the plaintiff. Furthermore, the defendant does have a right to conduct inventory of items and automatically repossesses or padlock the unit without judicial proceedings.
WHEREFORE, the defendant respectfully prays that the complaint be dismissed with costs against the plaintiff. 0000000000 LAW OFFICE Counsel for the Defendant Suite 123 The Tower Malate, Manila
By: DEL DIMANAHAN Roll No. 00000 IBP No, 0000/1-3-2012/Manila PTR No. 00000/1-3-2012/Manila
Copy furnished: ATTY. BLAH BLAH Counsel for the Plaintiff Unit 1234 Laurel Building Sampaloc, Manila 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.