Republic of the Philippines

Municipal TRIAL COURT

5th Judicial Region
Branch___
NAGA CITY

RAHOOL ANGHELLYES
Plaintiff,

-vs- Civil Case No. __________

For: Collection of Sum of Money

EDDIE WARD
Defendant.
x--------------------------------------------x

COMES NOW, the plaintiff, through the undersigned counsel and unto this
Honorable Court, most avers:

1. That the plaintiff denies the allegation of the defendants in Paragraph

2,3,4and 5 the truth being that defendant had agreed to said amount as
a matter of fact the defendant is the one who made the promissory note
and signed it

2. That plaintiff specifically denies the allegations in paragraph 5 the fact

being that the defendant had received the notice of demand by the
plaintiff and the defendant himself had receive it personally.

3. That Paragraphs 1 and 6 of defendants Special Affirmative defenses are

specifically denied, as they are far-fetched conclusions and convenient
inventions of the defendants to suit their own purposes, the real truth
of the whole matter being those that are alleged in the complaint;

WHEREFORE, it is most respectfully prayed that the answer and

affirmative defenses of the defendants be denied and overruled with costs against
the defendants and the prayer in the complaint be granted with such other reliefs
and favorable pronouncements in favor of the plaintiff that may be deemed just,
proper and equitable.

Naga City, ______________.

Heinrich Himmler
Counsel for Plaintiff
Packsheet Tower, Naga City
Roll No. 87432 IBP No. 863992
MCLE Compliance No. 11-00083469