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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


NATIONAL CAPITAL JUDICIAL REGION
Branch 40, MANILA
ALEXANDER SISON,
Plaintiff,
Civil Case No. 135684
For: Sum of Money

-versusJUAN JAMERO,
Defendant.
X-----------------------------------------X

MOTION
(TO DECLARE DEFENDANT IN DEFAULT)
Plaintiff, by counsel and unto this Honorable Court, respectfully
states:
1. The records of the Honorable Court show that Defendant was
served with summons and a copy of the complaint on January 30,
2009;
2. Upon verification however, the records show that Defendant has
failed to file his Answer within the reglementary period specified
by the Rules of Court despite the service of the summons and the
complaint;
WHEREFORE, it is respectfully prayed that Defendant be declared
in default for failure to file answer to the complaint within the reglementary
period of time pursuant to the Rules of Court.
Other reliefs just and equitable are likewise prayed for.
Makati City, Metro Manila, Philippines, February 15, 2009.

RUZZEL DIANE ODUCADO


Counsel for the Plaintiff.
CDE Building
Valeria St., Iloilo City
1

The Clerk of Court


Regional Trial Court
Manila
Juan Jamero - Defendant
222 Juan Luna St., Tondo
Metro Manila, Philippines
GREETINGS:
Please be notified that the undersigned will submit the foregoing
motion on Friday, February 20, 2009 at the customary hour for the
consideration and approval of the Honorable Court.
Makati City, Metro Manila, Philippines, February 15, 2009.

ATTY. RUZZEL DIANE ODUCADO