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REPUBLIC OF THE PHILIPPINES NATIONAL CAPITAL JUDICIAL REGION REGIONAL TRIAL COURT OF MAKATI Makati, Branch 123 PABLO

A. ESCOBAR, Plaintiff, Civil Case No.________ -versusFor : Damages

KEANU REEVES AND KEVIN BACON, Defendants.

X----------------------------------------------------X
ANSWER WITH CROSS CLAIM Defendants, through the undersigned counsel, most respectfully file their Answer in response to the Complaint of the Plaintiffs and interpose as well as their counterclaim against the latter, to wit: ADMISSIONS AND DENIALS 1. Paragraphs 1, 2, 3, 4, 5 , 6, 9, and 10,are admitted; 2. That Paragraph 7 is denied insofar as the allegation that the Mercedes Benz tried to beat a red light, the truth and the matter being that the Driver of the Mercedes Benz had a clear green signal to traverse Quirino Avenue. 3. The allegation in Paragraph 8 is denied. That the driver of the TOYOTA Fortuner by the name of KEANU REEVES was the one who tried to beat the red light, and due to his negligence he was able to hit

the front right of the MERCEDES which caused the latter car to swerve and smash into PLAINTIFF's MAZDA 3. 4. Paragraph 10 is denied. The truth and the fact being, that both of the owners of the MERCEDES and TOYOTA Cars went out to assess the damage, however, the driver and owner of the FORTUNER, KEANU REEVES, was the only one who admitted negligence and liability to pay the damages to both KEVIN BACON and PABLO ESCOBAR. 5. Paragraph 12 is denied. PLAINTIFF was able to contact DEFENDANT KEVIN BACON, and that both parties were able to arrive at an oral agreement that the vehicular accident was solely caused by CoDefendant KEANU REEVES. 6. Defendant Kevin Bacon is without knowledge of information sufficient to form a belief as to the truth of the allegations of Paragraphs 13 and 14. 7. That because of CO-defendant Keanu Reeves' negligence, DEFENDANT Kevin Bacon suffered an actual damage of 200, 000 pesos, which was the amount of reparation of the latter's Mercedes Benz. 8. Due to the complaint filed against Defendant, Kevin Bacon was forced to hire the undersigned as his counsel in the amount of 10,000.

PRAYER
WHEREFORE, in view of the foregoing, Defendants most respectfully pray for the award of 1. Actual damages in the amount of 200,000. 2. Attorneys fees in the amount of 10,000 3. Cost of Suit. Other reliefs are likewise prayed for.

ATTY. BRANDO D. TUAZON Counsel for DEFENDANT 2853 H. Santos St. Makati City

VERIFICATION AND CERTIFICATION


I, KEVIN BACON, of legal age, Filipino Citizen, single and resident of 58 Saturn St., Bel-Air,
Makati City. After having been duly sworn to in accordance with the law do hereby depose and

say:

1. That I am the DEFENDANT in the above-entitled case; 2. That I have caused the preparation of the foregoing complaint and have read the allegations contained therein; 3. The allegations in the said complaint are true and correct of my own knowledge and authentic records; 4. I hereby certify that I have not commenced any other action or proceeding involving the same issues in any court, tribunal or quasi-judicial agency and, to the best of my knowledge, no such other action or claim is pending therein; 5. That if I should learn thereafter that a similar action or proceeding has been filed or is pending, I hereby undertake to report that fact within five (5) days therefrom to the court or agency where the original pleading and sworn certification contemplated herein have been filed; 6. I executed this verification/certification to attest to the truth of the foregoing facts and to comply with the provisions of Adm. Circular No. 04-94 of the Honorable Supreme Court.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 20th of December 2012, in the City of Makati.

KEVIN BACON DEFENDANT

SUBSCRIBED AND SWORN to before me this 20th day of December 2012 in the City of Makati, affiant exhibiting to me his Community Tax Certificate No. 9294924 issued on June 16, 2012 in the City of Manila.

PEDRITO PALPAL Notary Public

My Commission Expires Dec. 31, 2013 IBP No.143535 1/19/2001, Makati City PTR No.98764 1/2/2001, Makati City

Doc. No. 454 Page No. 234 Book No. X Series of 2012

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