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  • Motion For Bill of Particulars W Aff

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    Jane Hearty
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    This document contains a motion for a bill of particulars filed by the defendant Jose Bo in the civil case of Juana Dela Cruz vs Jose Bo for allegedly violating Section 1 of the Anti-Bastos Law. The motion argues that the complaint contains conclusory allegations that do not provide enough specific facts and details to allow the defendant to adequately prepare a responsive pleading. The defendant requests that the plaintiff be ordered to file a bill of particulars clarifying the precise nature, character, scope, and extent of the alleged acts. A notice of hearing is also included, setting the motion for hearing on November 23, 2017.

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    Motion for Bill of Particulars w Aff

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    This document contains a motion for a bill of particulars filed by the defendant Jose Bo in the civil case of Juana Dela Cruz vs Jose Bo for allegedly violating Section 1 of the Anti-Bastos Law. The motion argues that the complaint contains conclusory allegations that do not provide enough specific facts and details to allow the defendant to adequately prepare a responsive pleading. The defendant requests that the plaintiff be ordered to file a bill of particulars clarifying the precise nature, character, scope, and extent of the alleged acts. A notice of hearing is also included, setting the motion for hearing on November 23, 2017.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
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    Download as docx, pdf, or txt
    32 views4 pages

    Motion For Bill of Particulars W Aff

    Uploaded by

    Jane Hearty
    This document contains a motion for a bill of particulars filed by the defendant Jose Bo in the civil case of Juana Dela Cruz vs Jose Bo for allegedly violating Section 1 of the Anti-Bastos Law. The motion argues that the complaint contains conclusory allegations that do not provide enough specific facts and details to allow the defendant to adequately prepare a responsive pleading. The defendant requests that the plaintiff be ordered to file a bill of particulars clarifying the precise nature, character, scope, and extent of the alleged acts. A notice of hearing is also included, setting the motion for hearing on November 23, 2017.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Flag for inappropriate content
    Download as docx, pdf, or txt
    of 4

    Republic of the Philippines

    Regional Trial Court

    National Capital Region

    Branch 7
    Juana Dela Cruz,

    Plaintiff,

    -versus-

    Jose Bo,

    Defendant.

    x - - - - - - - - - - - - - - - - - - - - - - - - -x

    Civil Case No 1654321

    FOR: Violating Sec. 1 of Anti-Bastos Law

    MOTION FOR BILL OF PARTICULARS

    Defendant, by counsel and to this Honorable Court, respectfully states:


    1. The complaint alleges that defendant a resident of Pasay City, together with herein
    defendant movant, had done offensive body gestures to the plaintiff, and exposing his
    private parts for the sexual gratification of the defendant, with the effect of harassing and
    threatening the offended party.
    2. The foregoing allegations are conclusions of law, which plaintiff should clarify and
    flesh them with facts and specific acts to enable defendant-movant to prepare and file a
    responsive answer thereto which requires information as to precise nature, character,
    scope and extent of plaintiff’s cause of action.

    WHEREFORE, defendant prays that plaintiff be ordered to file a bill of particulars of the facts
    and acts constituting the conclusions alleged in the complaint.
    ATTY. IVY ADORNADO

    Counsel for the Defendant

    NOTICE OF HEARING

    Atty. Ivy Adornado

    Counsel for the Defendant

    Bgry. San Pedro, Pasay City

    Ma’am:

    Please be informed that the undersigned counsel has set the foregoing Motion for
    Reconsideration for hearing on November 23, 2017 at 9:00 am, for the consideration of the
    Honorable Court or soon thereafter as counsel maybe heard.

    ATTY. KIM LIM

    Counsel for the Plaintiff

    Bgy. Sta. Cruz, Pasay Coty


    AFFIDAVIT OF PERSONAL SERVICE

    I, Petronel Marquez, of legal age and having been duly sworn depose and say:

    That I am the messenger of Atty. Ivy Adornado, Counsel for the defendant in the case entitled
    Juana Dela Cruz vs Jose Bo, Civil Case No. 1654321, and that such messenger I served upon
    the counsel of adverse party and other parties, the Motion for Consideration filed in said case,
    as follows:

    Atty. Bernardo U. Goy, counsel for the Plaintiff, by personal service by delivering personally
    copy of said Motion upon said lawyer who acknowledged receipt there of as shown by his
    rd
    signature or initial on the said pleading, this 23  day of October 2013
    th
    IN WITNESS WHEREOF, I have signed this affidavit this 24  day of October 2013 at Puerto
    Princesa City.

    _________________________________

    Affiant

    SUBSCRIBED AND SWORN TO BEFORE ME, A Notary public in and for the City of Puerto
    th
    Princesa and the Province of Palawan this 24  day of October 2013. Affiant personally came
    and appeared with Driver’s License ID No. issued by the Land Transportation Office and valid
    until May 1, 2015, at Puerto Princesa City, bearing his photograph and signature, known to me
    as the same person who personally signed the foregoing instrument before me and avowed
    under penalty of law to the whole truth of the contents of said instrument

    _________________________________

    Notary Public

    Doc. No. ______;


    Page No. ______;

    Book No. ______;

    Series of 20__;

    Copy furnished:

    ATTY. KIM LIM

    Counsel for plaintiff

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