Republic of the Philippines

REGIONAL TRIAL COURT

6th Judicial Region
Branch 12
Makati City

Monkey D Luffy Plaintiff, CIVIL CASE No. 16-0956-2341

- versus – FOR: COLLECTION OF SUM OF

MONEY.

Trafalgar Law Defendant.

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MEMORANDUM FOR
PLAINTIFF

Plaintiff, by counsel, respectfully states that:

STATEMENT OF THE CASE

Plaintiff Monkey D. Luffy (hereinafter “Luffy”) filed the present action for Collection
of Sum of Money against Defendant Trafalgar Law. Trafalgar attributes the injuries suffered
by her minor son to Gloria Supermart’s gross negligence in failing to make its premises safe
for customers, thereby making it liable under Art. 2176 and Art. 2180 of the Civil Code.
Defendant maintain that whatever injuries and expenses that were incurred by the Bueno
family can be attributed to Jonna’s failure to supervise her child.