Of the Defendant

Defendant Luke Brandon is willing to

enter into an amicable settlement
on terms which are just and
equitable in the premises.

The identity and legal capacities of the
plaintiff and the defendant to sue and be
sued;
The plaintiff is a lessee of the house and
lot, and there is a contract of lease
between her and the previous owner;
The defendant purchased the property
and became the absolute owner and
subsequent lessor;
The due existence of the demand letter to
vacate dated February 2, 2013;

The plaintiff is no longer a lessee and has
become an unlawful detainee for failure
to pay the rent despite oral and written
demands to pay and demand to vacate
and that he may be ousted by the owner
for such failure to pay;
The plaintiff having no legal standing to
ask for a writ of preliminary injunction for
there is no status quo to be preserved;

The defendant has made oral and written
demands to pay the rentals, the
defendant demanded that the plaintiff
leave the premises;
The lessor may eject the lessee for lack
of payment of the price stipulated and
violation of the terms of the contract of
lease;

1. Whether or not the defendant is
entitled for damages;

2. Whether or not to dissolve the Writ
of Preliminary Injunction;

The original copy of the Contract of
Lease executed between the
plaintiff and the previous owner;

Demand Letter to pay the rentals
addressed to Rebecca Bloomwood,
dated December 6, 2012 and the
last demand letter dated January 6,
2013 as Annex 1 and Annex 1-A;

Luke Brandon

Jarquin Sturt previous owner of the
property


Respectfully submitted for the
consideration of this Honorable Court.





Ilolo City, Philippines, March 25, 2013