Republic of the Philippines

Regional Trial Court,

Branch 40, Quezon City

LEBRON CURRY

Plaintiff,

-versus- Civil Case No.7965

For a sum of money
STEPHEN JAMES

Defendant

COMPLAINT

Plaintiff, by undersigned counsel and to this Honorable Court, respectfully states:

1. Plaintiff Lebron Curry is of legal age, married, and with residence at 58 Black
St., Quezon City, while defendant Stephen James is also of legal age, married, and
with residence at 89 Fright St., Quezon City, where he may be served with summons
and other legal processes.

2. On April 25, 2014, defendant borrowed Two Million pesos ( P 2,000,000.00)

from plaintiff, with interest thereon at 12% per annum, payable on or before April 25,
2015, as evidenced by a promissory note, which he executed and which he provides :

P1,000,000.00 April 25, 2014

“For value received, I hereby promise to pay Lebron Curry at his residence
at 58 Black St., Quezon City, the sum of Two Million (P2,000,000.00) with
interest thereon at 12% per annum from April 25, 2014, payable on or before
April 25, 2014. In the event I fail to pay said amount, including its stipulated
interests, I agree to pay him, as attorney’s fees and expenses of litigation, the
sum of Four Hundred Thousand pesos (P400,000.00)

Stephen James
Borrower

True copy of said promissory note is attached hereto and made an integral
part hereof as Annex “A.”

3. The due date, April 25, 2015, of said promissory note (Annex “A”) arrived, and
yet defendant failed to pay the said amount of P 2,000,000.00, in breach thereof.

4. Notwithstanding demands, both verbal and written, made upon defendant, the
latter failed and refused and continues to refuse to pay his lawful obligation.

5. As a result of defendant’s breach of obligation to pay his indebtedness, as

well as the stipulated interests thereon, plaintiff was constrained to secure the services
of counsel to protect his interest and to file the complaint and to incur attorney’s fees
and expenses of litigation, in the amount of P400,000.00, which should be assessed
against defendant.

WHEREFORE, plaintiff respectfully prays that judgment be rendered ordering

defendant to pay plaintiff the amount of P2,000,000.00 with interest thereon at 12% per
annu8m starting April 25, 2014 until fully paid, as well as the sum of P400,000.00 as
and for attorney’s fees and expenses of litigation , plus costs.

Plaintiff further prays for such other reliefs as may be just and equitable in the
premises.
 Quezon City, June 25, 2015.

Counsel. Form No. 8

VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, Lebron Curry, of legal age, and with residence at 58 Black St. Quezon City, after
having been duly sworn in accordance with law, depose and state that:

1. I am a plaintiff in the above-stated case;

2. I caused the preparation of the foregoing complaint;

3. I have read the contents thereof and the facts stated therein are true and correct of
my personal knowledge and/or on the basis of copies of documents and records in my
possession;

4. I have not commenced any other action or proceeding involving the same issues in
the Supreme Court, the Court of Appeals, or any other tribunal or agency;

5. To the best of my knowledge and belief, no such action or proceeding is pending in

the Supreme Court, the Court of Appeals, or any other tribunal or agency;

6. If I should thereafter learn that a similar action or proceeding has been filed or is
pending before the Supreme Court, the Court of Appeals, or any other tribunal or
agency, I undertake to report that fact within five (5) days therefrom to this Honorable
Court.

LEBRON CURRY
Affiant

UBSCRIBED AND SWORN to before me this 25th day of March 2016 at Quezon City affiant
exhibiting to me his Community Tax Certificate No.1678945 issued on March 23, 2016 at
Quezon City.

Doc. No. ;56

Page No. ;23
Book No. ;45
Series of 2016.