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COMPLAINT

COMES NOW the plaintiff, by the undersigned counsel, and unto this Honorable
Court, respectfully alleges:

1. That both the plaintiff and the defendant are of legal age and residents of
_________________________;

2. That ______________________ (state facts which constitute an action for the


recovery of money on a cause of action arising from contract, etc.);

3. That the defendant is about to remove or dispose of his property, with intent to
defraud his creditors;

4. That the plaintiff is willing to put up a bond for the issuance of a preliminary
attachment in an amount to be fixed by the court, not exceeding the sum of P_______
which is the plaintiff's claim herein.

WHEREFORE, it is respectfully prayed that, pending the hearing of the 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 after due
hearing on the principal cause of this action, judgment be rendered against the
defendant for the sum of P_________, with interest at the stipulated rate of ____% from
_____________, plus costs of this suit.

Mandaluyong City, ____________________, 2004.

Counsel for the Plaintiff

(Address, IBP No. and Roll No.)

AFFIDAVIT FOR PRELIMINARY ATTACHMENT

REPUBLIC OF THE PHILIPPINES ) CITY OF MANDALUYONG ) S.S.

I, _________________, of legal age, single/married, and a resident of


_________________, after having been duly sworn to according to law, hereby depose
and say:

That I am the plaintiff in the above-entitled case;

That a sufficient cause of action is one of those specifically mentioned in Section 1 of


Rule 57 of the Rules of Court, whereby a writ of preliminary attachment may issue, to
wit__________________________;

That there is no other sufficient security for the claim sought to be enforced by the
present action;

That the amount due to the plaintiff is as much the sum for which an order of
attachment is sought to be granted, above all legal counterclaims on the part of the
defendant.