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CAROLINE L. TABAMO,
Plaintiff, CIVIL CASE. NO. _____
-versus-
FOR: COLLECTION OF SUM
AILEEN P. DORING OF MONEY, ATTORNEY’S FEES
Defendant.
x------------------------------------x
ANSWER
5. That while there is truth, as to the claim of the Plaintiff that the
Defendant was indebted to her in the amount of Php 350,000.00,
however, the said debt was already paid and settled by the
Defendant, as evidenced by the receipt duly signed by the Plaintiff;
Copy of which was previously marked as Annex "1";
6. That the Defendant has never borrowed money from the Plaintiff
aside from that one which was already settled; If indeed the
Defendant incurred another obligation from the Plaintiff, the latter
should have presented any evidence or proof of indebtedness; Worth
to note in the Complaint, however, there was no document attached
thereto evidencing that indeed the Defendant was indebted to her;
7. That the Plaintiff could not merely declare and allege that the
Defendant borrowed money to her considering the amount she is
claiming in her Complaint; she should have attached proof thereto
to substantiate and support her claim;
9. That there being no proof evidencing the claim of the Plaintiff it can
be inferred that this case is simply intended to harass and destroy
the reputation of the Defendant;
NELIE G. CONSEBIT
Counsel for the Defendant
PTR No. SK 1599891 1/02/18
IBP No. 824958 1/02/18
Roll No. 50208
TIN 742-815-133
Isulan, Sultan Kudarat
MCLE V Compliance No. 23515
VERIFICATION AND
CERTIFICATION OF NON-FORUM SHOPPING
I, AILEEN P. DORING, of legal age, Filipino, and a resident of Purok
Rosal, Barangay New Carmen, Tacurong City, after having been duly sworn
to an oath in accordance with law, do hereby depose and says:
AILEEN P. DORING
Affiant
ID No. ----------
NELIE G. CONSEBIT
Notary Public
PTR No. SK 1599891 1/02/18
IBP No. 824958 1/02/18
Roll No. 50208
TIN 742-815-133
Isulan, Sultan Kudarat
MCLE V Compliance No. 23515
Copy furnished:
RECEIPT
Received from Aileen P. Doring the amount of THREE
HUNDRED FIFTY THOUSAND PESOS (P 350,000.00)
representing her payment for the debt she owed me.
CAROLINE L. TABAMO
(Signed)
Conforme:
AILEEN P. DORING
(Signed)