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CHRISTINE SY,
Plaintiff,
versus
LEONORA DELA CRUZ and
TERESA SANTOS,
Defendants.
/----------------------------------------------------------/
COMPLAINT
Plaintiff, by counsel, to this Honorable Court, most
respectfully sets forth that:
1. Plaintif is of legal age, Filipino citizen, single, a resident of ,
Block 7, Lot 37, Ibalong Village, Taysan, Legazpi City, and
with capacity to sue and be sued. The Honorable Courts
notices, order and other processes may be sent to Almojuela
Law Office at Pearanda Ext. St., Bonot, Legazpi City 4500.
2. Defendant LEONORA DELA CRUZ is of legal age, Filipino
citizen, married, with capacity to sue and be sued, and a
resident of of Inner Court Subd., Molave St., Washington
Drive, Legazpi City, Albay where she may be served with
Summons, a copy of this Complaint, and other Courts
processes.
3. Defendant TERESA SANTOS is likewise of legal age, Filipino
citizen, married with capacity to sue and be sued, and a
resident of 215 Diego Silang St., Maoyod, Legazpi City where
she may be served with Summons, a copy of this Complaint,
and other Courts processes.
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10.
As a consequence of defendants failure to pay despite
repeated demands, plaintiff was deprived of her right to
recover the loaned amount and accrued interest.
In
addition, she was compelled to secure the services of a
lawyer to protect her interest and enforce her rights and thus
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PRAYER
WHEREFORE, plaintiff respectfully prays for judgment
from the Honorable Court ordering defendants:
1.
2.
3.
4.
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NOTARY PUBLIC
UNTIL __________
FOR AND IN THE PROVINCE OF ALBAY
MCLE COMPLIANCE NO. _________/_________
PTR No.____________;___________; Leg. City
IBP No. __________; __________; Albay
ATTORNEYS ROLL NO. ___________
Serial/Docket No. ____________