REPUBLIC OF THE PHILIPPINES PROVINCE OF CAVITE CITY OF BACOOR

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S.S.

COMPLAINT FOR REPLEVIN WITH PRAYER FOR PRELIMINARY ATTACHMENT

I, Andy Lim, of legal age, single, and resident of 398 Dion st. Sto. Tomas Village, Bacoor city, Cavite, Philippines, after being sworn in accordance with law, depose and say: 1. That I am the plaintiff in an action for the delivery of personal property against the defendant, entitled Andy Lim v. Panfilo Guerrero in the Regional Trial Court of Bacoor; That I am the owner of a automobile, particularly described as follows, as to wit: MAKE: MOTOR NO.: SERIES: SERIAL/CHASSIS NO.: TYPE OF BODY: PLATE NO.: YEAR MODEL : FILE NO.: C.R. NO.: 3. 4. Datsun 3822382719 Fairlady-240z 2389721 2-door fastback NIS-240 1975 121873 238213

2.

5.

That the said automobile is wrongfully detained by the defendant, without any lawful cause whatsoever; That the said property has not been taken for tax assessment or fine pursuant to law, or seized under an execution, or an attachment against the property of the plaintiff; That the actual value of the said personal property has increased through improvements and rarity and is valued at one million, two hundred and forty-five thousand Philippine pesos (Php 1,000,000.00)

WHEREFORE, it is respectfully prayed that pending the hearing of this case, a writ of preliminary attachment be issued against the property of the defendant to serve as security for the satisfaction of any judgment that may be recovered herein; and that after due hearing on the principal cause of action, judgment be rendered against defendant for recovery of the said automobile in his possession

__________________ Andy Lim Plaintiff SUBSCRIBED and sworn before me, in the city of Bacoor, this 11 th day of December, 2013, by Atty. Lawrence Emmanuel Solis with Residence Certificate No. 0933120 issued at Talaba IV, Bacoor city, on January 9, 2013. Atty. Lawrence Emmanuel C. Solis, NOTARY PUBLIC My commission expires Dec. 31, 2013 Doc. No. ______; Page No.______; Book No.______; Series 2014