Answer With Negative and Affirmative Defenses
Answer With Negative and Affirmative Defenses
LORELEI G. LOPEZ ,
Plaintiff,
-versus- CIVIL CASE NO. CC-09871
FOR: Collection of Sum of
Money
LORNA R. FERNANDEZ,
Defendant.
x----------------------------------------------------x
4. Assuming, further, that the agent who signed the promissory note on
behalf is duly authorized to do so, the amount of indebtedness therein
stated represented payment of gambling losses of defendant in favor of
plaintiff.
PRAYER
WHEREFORE, defendant respectfully prays that the complaint be dismissed for
lack of merit, with costs against plaintiff.
Defendant further prays for such relief as may be just and equitable in the
premises.
VERIFICATION
1. That I caused the preparation of the foregoing answer with defenses, and
the allegations therein are true and correct of her personal knowledge
and/or based authentic records.
2. Those I further states that the promissory note, Annex “A” of the
complaint, is a forgery and her signature therein has been forged, she not
having executed the said promissory note.
LORNA R. FERNANDEZ
Defendant/Affiant
SUBSCRIBED AND SWORN to before me in the City of Baguio this 30th day of
August 2014 by LORNA R. FERNANDEZ, personally known to me, who is the same
person who personally signed before me the foregoing affidavit and acknowledged that
she executed the same.
NOTICE
Copies of this answer were personally filed and delivered to:
-and-