Republic of the Philippines

REGIONAL TRIAL COURT

FIRST JUDICIAL REGION
Branch 8
Baguio City

AJ REALTY CORPORATION
Plaintiff,
Civil Case No. 0246
-versus - For: Collection of Sum of Money

ANDREW VILLANIA,
Defendant.
x------------------------------------x

MOTION FOR BILL OF PARTICULARS

Defendant, through the undersigned counsel and unto this Honorable Court, avers:

1. That the plaintiff's complaint in paragraph 5 alleges:

From APRIL 3 to OCTOBER 2012, defendant never paid anything

to herein plaintiff. The check that he issued as partial payment for
the first month also bounced. x x x(underscoring supplied)

2. The said allegation is not averred with sufficient definiteness and particularity,
specifically it does not mention the amount of the check therein mentioned, its check
number, date, and the drawee bank;

3. That a more definite statement on the matters as above-indicated is necessary in order to

enable the defendant to prepare its responsive pleading because from the very onset of
this controversy, the main dispute was on what was actually and exactly agreed upon by
the parties as the amount of monthly rentals on the lease of plaintiff's property;

4. However, due to the fact that defendant corporation had to transfer its liaison offices
depending on its project sites, the check stub where the above-mentioned check came
from was probably misplaced and could no longer be found;

5. That a bill of particulars or a more definite statement as to particulars of the said check
which was allegedly issued by the defendants as partial payment for the first month
would definitely simplify the issues in this case, and hopefully uncomplicate the
negotiations between the parties for an amicable settlement.

PRAY E R

WHEREFORE, defendant most respectfully prays that an order be issued by this

Honorable Court requiring the plaintiff to make more definite statement as to the particulars of
the check mentioned in paragraph 5 of his complaint, particularly stating its amount, check
number, date, and the name of the drawee bank.

Baguio City, Philippines this 17th day of January 2014.

 JO-ANNE M. VENTIGAN
Attorney for the Defendant
4F La Azotea Bldg., Session Road, Baguio City
Tel No.: (074)-442-3396
PTR No. 22222; 1/07/2012; Baguio City
IBP OR No: 7654321; 1/07/2012; Baguio City
Roll No.: 82112; 4/08/2004
Serial No.: 74-NC-12 (R)
MCLE Compliance No.: IV-34458; 04/28/2012
TIN No: 802-112-107

Copy Furnished:

ATTY. JOSELITO AGBUGGO

Attorney for the Plaintiff
G/F Park Bldg., Camp 7, Tuba,
Benguet Province

EXPLANATION:

Copy of the foregoing Motion was served through registered mail due to distance and
lack of personnel to effect personal service.