Plaintiff: Complaint For Replevin / Recovery of Personal Property
Plaintiff: Complaint For Replevin / Recovery of Personal Property
QWERTY, INC.
Plaintiff
8. Despite the foreclosure however, and despite notice and demand to the
Defendant to surrender the subject motor vehicle subject to foreclosure,
Defendant failed and continued to fail to surrender the same without
any legal or justifiable cause. A copy of said demand letter dated June
1, 2011 is hereto attached as Annex “E”;
11. That the property has not been distrained or taken for a tax assessment
or a fine pursuant to law, or seized under writ of executed or
preliminary attachment, or otherwise placed under custodial egis, or if
so seized, that it is exempt from such seizure or custody;
12. Plaintiff is ready, willing and able to put up a good and solid bond of
double the actual market value of the above-described motor vehicle
conditioned on the return of the same to the Defendant is such is
adjudged, and for the payment of such sum as they may recover from
the Plaintiff in the instant action.
PRAYER
3. In either case, to order defendant to pay plaintiff the sum of Ten (10%)
of the total amount due as Attorney’s Fees, and to reimburse plaintiff
its expenses as may be proved during the trial, and other expenses
incurred in the seizure of the said motor vehicle, and the cost of the suit.
EARNSWELL P. TAN
Counsel for the Plaintiff
Roll No. 12345
IBP NO. 946492 – 1/1/2017
PTR NO. 564800 – 1/1/2017
Tan Law Office, Abgao, Maasin City, Southern Leyte
REPUBLIC OF THE PHILIPPINES)
MAASIN CITY ) s.s.
VERIFICATION / CERTIFICATION
1. I am a the Manager of SINE QUA NON, INC, the plaintiff in the above-
captioned case which is for replevin / recovery of possession of the
motor vehicle Chevrolet Corvette Stingray 2014 Model, registered in
the name of the defendant;
4. That the property has not been distrained or taken for a tax assessment
or a fine pursuant to law, or seized under writ of executed or
preliminary attachment, or otherwise placed under custodial egis, or if
so seized, that it is exempt from such seizure or custody;
5. Plaintiff is ready, willing and able to put up a good and solid bond of
double the actual market value of the above-described motor vehicle
conditioned on the return of the same to the Defendant is such is
adjudged, and for the payment of such sum as they may recover from
the Plaintiff in the instant action;
7. That I further certify that: (a) I and plaintiff have not theretofore
commenced any other action or proceeding involving the same matter
in the Supreme Court, the Court of Appeals, or any other tribunal or
agency; (b) to the best of my knowledge, no such action or proceeding
is pending in the Supreme Court, the Court of Appeals, or any other
tribunal or agency, I and the corporation undertake to report such fact
within five (5) days therefrom to the court or agency wherein the
original pleading and sworn certification contemplated herein have
been filed.
EARNSWELL P. TAN
Notary Public for Maasin City
Roll No. 12345
IBP NO. 946492 – 1/1/2017
PTR NO. 564800 – 1/1/2017
Doc. No.
Page No.
Book No.
Series of 2014