Professional Documents
Culture Documents
08-8-7-SC
FORM 3-SCC
EMMANUEL E. SANDICHO,
Defendant.
x- - - - - - --- - - - - - - - - - - - -x
RESPONSE
2. Defendant specifically denies that he still owes the plaintiff any sum of
money as he has already paid all obligations to the plaintiff by way of
payroll deductions collected by a designated “Pay Master” who served as
“collection agent” of the plaintiff. The said “Pay Master” issued post-
dated checks to the plaintiff to cover the payments made by defendant as
well as group co-borrowers. NOTABLY IN THE PREVIOUS ACTIONS FILED
BY PLAINTIFF, IT HAS ATTACHED PERTINENT DOCUMENTS SHOWING
THAT THE CHECKS ISSUED BY ITS PAY MASTER AND/OR COLLECTING
AGENT PERTAIN TO THE ALREADY COLLECTED LOAN AMORTIZATIONS
OF DEFENDANT AND HIS CO-BORROWERS.
3. Defendant opposes the grant of the prayer in the Statement of Claim for
the following reasons, as supported by the attached documentary proofs:
PAGE 1 OF 3 - RESPONSE (EMMANUEL SANDICHO)
PRAYER
EMMANUEL E. SANDICHO
DEFENDANT
PAGE 2 OF 3 - RESPONSE (EMMANUEL SANDICHO)
EMMANUEL E. SANDICHO
Affiant