REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
BRANCH 1, QUEZON CITY

Juan Apol
Plaintif,

-versus- CIVIL CASE NO. M-2017-123

For: Sum of money and
damages

Pedro Bayabas

Defendant.
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WRITTEN INTERROGATORIES

TO: MR. PEDRO BAYABAS, Defendant

FROM: MR. JUAN APOL, Plaintif

Instructions
Pursuant to Rule 25 of the Rules of Court, you are requested
to answer within fifteen (15) days the following interrogatories.

a) In accordance with Rule 25 Section 2, your response shall be

answered fully in writing and shall be signed and sworn by
you.

b) Also in accordance with Rule 25 Section 2, you shall file and

serve a copy of the answers within fifteen (15) days after
service thereof, unless the court on motion and for good
cause shown, extends or shortens the time.

c) If in answering these interrogatories, you encounter any

ambiguities in construing a question, instruction, or definition,
set forth the matter deemed ambiguous and the construction
used in writing.

Definitions

1
a) Where the name or identity of a person is requested, please
state the full name, home address, and also business address,
if known.

b) Unless otherwise indicated, these Interrogatories refer to

time, place, and circumstances of the occurrence mentioned
or complained of in the pleadings.

c) Where knowledge of information or possession of a party is

requested, such request includes knowledge of the partys
agents, representatives and, unless privileged, his attorneys.
When answer is made by a public or private corporation or a
partnership or association, state the name, address, and title
of the person supplying the information, and making the
affidavit, and the source of his information.

d) The pronoun you refers to the party whom these

Interrogatories are addressed, and the persons mentioned in
clause (c).

Interrogatories

1. Please state the name, law firm address, and your

relationship with the person who helped you in the
preparation of this document.
2. What is your relationship with the Plaintif?
3. What is the exact amount that the Plaintif deliver to
you?
4. Are you aware of the maturity date as indicated in the
contract?
5. Did you receive the demand letter sent by the Plaintif?

Quezon City, Philippines, February 15, 2017.

ATTY. JOEL ARZAGA

Counsel for the Plaintif.
Unit 123, 3rd Floor,

999 Building, Quezon City