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1) Michael Corleone filed a complaint against Bruno and Maria Tattaglia for unlawful detainer of a mansion located in Long Island, New York City.
2) In 2006, Corleone sold the mansion to the Tattaglias for $2.5 million but allowed them to occupy it before full payment on the condition they pay the remaining $338,000 balance.
3) Corleone demanded payment of the balance in 2010 and 2013 but the Tattaglias refused to pay or vacate, so Corleone cancelled the sale agreement and now seeks to have the court order the Tattaglias to vacate and pay rent and damages.
1) Michael Corleone filed a complaint against Bruno and Maria Tattaglia for unlawful detainer of a mansion located in Long Island, New York City.
2) In 2006, Corleone sold the mansion to the Tattaglias for $2.5 million but allowed them to occupy it before full payment on the condition they pay the remaining $338,000 balance.
3) Corleone demanded payment of the balance in 2010 and 2013 but the Tattaglias refused to pay or vacate, so Corleone cancelled the sale agreement and now seeks to have the court order the Tattaglias to vacate and pay rent and damages.
1) Michael Corleone filed a complaint against Bruno and Maria Tattaglia for unlawful detainer of a mansion located in Long Island, New York City.
2) In 2006, Corleone sold the mansion to the Tattaglias for $2.5 million but allowed them to occupy it before full payment on the condition they pay the remaining $338,000 balance.
3) Corleone demanded payment of the balance in 2010 and 2013 but the Tattaglias refused to pay or vacate, so Corleone cancelled the sale agreement and now seeks to have the court order the Tattaglias to vacate and pay rent and damages.
1. The plaintiff is of age, married and a resident of Long Island, New Yark City. The defendants are also of age, with residence at Northern, Sicily City, where they may be served with summons and other court processes;
2. The plaintiff is an agent and partly owner of a mansion located at Long Island, New Yark, currently being occupied by the defendants; 3. On January of 2006, the plaintiff and the defendants executed a Deed of Absolute Sale for the said house and lot amounting to P2.5 million;
4. The full amount was not paid but defendants were allowed by the plaintiff to occupy the premises agreeing that the title will only be transferred upon the payment of the balance amounting P338,000.00;
5. On August 2, 2010, the plaintiff legally demanded for the unpaid balance.
6. On April 15, 2013, a final demand to pay and vacate was sent, but the defendants refused to comply. Thus, the Deed of Absolute Sale was cancelled resulting to the illegal possession of the house and lot by the defendants. The plaintiff also demanded for the payment of monthly rentals; 7. By reasons already mentioned, the plaintiff was compelled to file this complaint, resulting for the need of legal service.
PRAYER. WHEREFORE, premises considered, it is most respectfully prayed unto this Honorable Court that, after hearingthe case, plaintiff requests judgment against the defendants:
a. To vacate the said property; b. To pay the monthly rentals, legal interest, forfeiture of agreement/ illegal possession of the premises; c. To pay the costs of the suit; d. To pay costs incurred in the proceeding; e. Any further relief that the court may consider just and proper
Other reliefs just and equitable are likewise prayed for. New Yark, Philippines, April 24 2014.
Glenn David Butardo Counsel for the Plaintiff PTR-1234567; 1-02-2014; New Yark City IBP-429053; 1-06-2013, New Yark City Roll 22 MCLE IV-99999 Unit No. 1, Godfather corner Marlon Brando St., Mario Puzo subdivision, New Yark City, Philippines Long Island
VERIFICATION/CERTIFICATION OF FORUM SHOPPING
Republic of the Philippines
I, MICHAEL CORLEONE, of legal age, Filipino citizen, single and resident of Long island, New Yark City, after having been duly sworn to in accordance with law do hereby depose and say:
1. That I am the plaintiff in the above-entitled case; 2. That I have caused the preparation of the foregoing complaint and have read the allegations contained therein; 3. The allegations in the said complaint are true and correct of my own knowledge and authentic records; 4. I hereby certify that I have not commenced any other action or proceeding involving the same issues in any court, tribunal or quasi-judicial agency and, to the best of my knowledge, no such other action or claim is pending therein; 5. That if I should learn thereafter that a similar action or proceeding has been filed or is pending, I hereby undertake to report that fact within five (5) days therefrom to the court or agency where the original pleading and sworn certification contemplated herein have been filed;
6. I executed this verification/certification to attest to the truth of the foregoing facts and to comply with the provisions of Adm. Circular No. 04-94 of the Honorable Supreme Court.
IN WITNESS WHEREOF, I have hereby affixed my signature this March, 6 2014, in the City of NewYark
MICHAEL CORLEONE
I, Glenn Butardo, am the Counsel in the above-entitled action. I have read the foregoing Complaint and know the contents thereof. The same is true of my own knowledge, except as to those matters which are therein alleged on information and belief, and as to those matters, I believe it to be true. I declare under penalty of perjury that the foregoing is true and correct and that this declaration was executed at Long Beach, California . ATTY. Glenn D. Butardo Attorney at Law My Commission Expires June. 6, 2226 Roll of Attorney No. 666 PTR-1234567; 1-02-2014; New Yark City IBP-429053; 1-06-2013, New Yark City Doc. No. ________ Page No. _______ Book No. _______ Series of 2014