COMPLAINT-AFFIDAVIT

THE UNDERSIGNED COMPLAINANTS-AFFIANTS xxx

and xxx, both of legal age and residing at xxx St., xxx
Subdivision, xxx, xxx, xxx City, under oath, respectfully
state:

1. RESPONDENT. – The Respondent in this criminal

complaint is xxx, of legal age, married, Filipino, and
resident of Block xxx, Lot xxx, xxx St., xxx Xxx, xxx,
xxx, xxx, where summons/subpoenas may be served
by this Honorable Office for purposes of preliminary

2. CRIME CHARGED. – The herein Complainants

hereby charge the abovenamed Respondent for the
crime of Perjury under Art. 183, Rev. Penal Code, the
ultimate facts of which are discussed hereinbelow.

3. ULTIMATE FACTS. – On 14 December 2015, the

Respondent executed a Sworn Statement before
Asst. City Pros. xxx of the Office of the City Prosecutor
of xxx. A copy of the said sworn statement, together
with the related documents thereto (e.g., Police
Referral, dated 14 December 2015; Barangay
Kasunduan, dated 7 October 2015; Final Demand
Letter, dated 12 November 2015; and Special Power
of Attorney, dated 14 December 2015) are attached
hereto as Annex “A”, with sub-markings. In the said
sworn statement, the Respondent charged the herein
Complainant XXX for the alleged crime of Estafa. It
was docketed as xxx, entitled “xxx vs. xxx”. It is
undergoing preliminary investigation before Asst. City
Prosecutor xxx.
3.1. In Question and Answer Nos. 4, 6, and 7 of the
said Sworn Statement of the Respondent, he
perjuriously alleged the following statements of
material facts under oath:

“x x x.

O4. T – Bakit mo e-reklamo (sic) yung taong iyong

nabanggit? (i.e., herein Complainant xxx).

S - Dahil po sa hindi pag bayad sa akin ng

perang hiniram nya na nagkakahalagang
PhP326,000.00.

O5. T - Kailan, saan, at anong oras naganap

ang sinasabi mong pangyayari?

S - Ganito po yun noong petsang

nabanggit at nagkasundo po kami ni xxx na
magnenegosyo kung saan magpapahiram po kami
sa kasamahan niyang xxx (sic) at may tubo poi to,
kaya sinimulan po namin ito sa akin po siya
kumukuha ng pera at siya ang nagpapalabas,
noong unang buwan at maganda pa ang negosyo
namin at bumabalik and puhunan ngunit dumaan
na ang ilang buwan kumukuha siya ng pera sa akin
ngunit hindi na ito bumabalik kasama na ang tubo at
umabot na poi to ng halagang PhP326,000.00 at
noong kinausap ko na po siya ay puro kanalang
PANGAKO NG PANGAKO (sic).”

X x x.”
3.2. The aforecited statements of the Respondent xxx
under oath were false and perjurious, the truth of the
matter being that the Estafa complaint filed by the
Respondent (as Complainant therein) in the
aforementioned case against the herein
Complainant XXX (as Respondent therein) was a
perjurious, malicious, felonious, baseless, unfounded
and unjust FABRICATION intended by the Respondent
XXX: (a) To collect a loan that the herein
Complainants had already paid in full; and (b) To
earn unjust, huge and usuri0us interests and/or
penalties/surcharges on the said fully paid loan,
without any legal and contractual basis therefor, and
solely for the selfish financial gain and benefit of the
Respondent SAMPAMNG and his anonymous
Financier.

3.3. The truth of the matter is that: The Complainant

XXX does not owe any amount whatsoever to the
Respondent XXX ; and The act of the Respondent
XXX of initiating the aforementioned Estafa case
against the herein Complainant XXX, without any
legal and factual basis, has caused him to suffer
mental anguish, extreme anxieties, sleepless nights,
and besmirched reputation on the part of the herein
Complainants.

3.4. The CHRONOLOGY OF RELEVANT FACTS AND

EVENTS in support of this Complaint for Perjury as
discussed hereinbelow.

3.5. On 20 September 2014 or thereabout, the

Complainant XXX was in need of P15, 000.00 for the
tuition fees of his child enrolled at the xxx. He sought
the assistance of the Respondent. The Respondent
 said he could lend the herein Complainant XXX the
amount the latter needed. The Respondent said he
had enough personal savings to accommodate the
urgent need of the Complainant XXX. The
Respondent did not mention that he would source
the amount from an outside Financier.

3.6. On 30 September 2014, when the herein

Complainant XXX was ready to pay in full his said
P15, 000.00 loan, the Respondent demanded an
additional amount of P6, 000.00 as interest on the
P15, 000.00 principal loan for the period of ten (10)
days. The Respondent alleged that the said amount
was being required by his anonymous Financier. The
herein Complainant XXX was surprised by such a
statement of the Respondent because the latter had
earlier said that the amount of P15, 000.00 was the
Complainant’s own personal savings. The
Complainants started to suspect the honesty of the
Complainant. The P6, 000.00 interest on the P15,
000.00 principal loan for a very short period of ten
(10) days was usurious, unacceptable,
unconscionable, iniquitous, and immoral.
Nonetheless, to avoid unnecessary interpersonal
problems with the Respondent, the Complainants
paid, via a deposit to the bank account of the
Respondent, to the Respondent the principal loan of
P15,000.00 and the interest of P6, 000.00 that the
Respondent and his anonymous Financier were
demanding.

3.7. As earlier stated, the Complainants paid the

Respondent on 30 September 2014 the total amount
of P21, 000.00, broken down as follows: (a) P15, 000.00
as principal loan; and (b) P6, 000.00 as
 interest. Please note that the said P6, 000.00 interest
amounted to an incredible, usurious, iniquitous,
unconscionable and immoral forty percent (40%)
interest rate for the very short period of ten (10) days
(i.e., 20 September 2014 to 30 September 2014).

3.8. The abovementioned verbal loan transaction

involving a principal amount of P15, 000.00 that took
place on 20 September 2014 was not evidenced by
any promissory note, contract of loan, voucher,
official receipt, or similar financial or contractual
document. It was a verbal loan transaction. There
was no oral or written stipulation whatsoever as to the
interest, penalties, or surcharges of the said verbal
loan. Please note, too, that the Respondent did not
attach to his Estafa Complaint any promissory note,
contract of loan, voucher, official receipt, or similar
financial or contractual document to prove his claim
against the herein Complainants. What were
attached to the Respondent’s Estafa Complainant
were only the following documents: (a) Barangay
“Kasunduan” dated 7 October 2015 between the
Complainant and the Respondent; (b) Final Demand
Letter, dated 12 November 2015, which was based
solely on the Barangay “Kasunduan”; and (c) Special
Power of Attorney (SPA), dated 14 December 2015,
executed by the Respondent in favor of XXX (his
daughter) and XXX (his sister) on the pretext that he
would be going abroad soon.

3.9. Two (2) weeks after 30 September 2014 (the date

when the herein Complainants paid to the
Respondent the said amount of P21,000.00) -- or
sometime in the middle of October 2014, -- the
Respondent called up the Complainant alleging: (a)
 That his anonymous Financier (whom the
Complainant did not identify) had allegedly rejected
the payment of P21, 000.00 earlier made by the
Respondent; and (b) That the unidentified Financier
of the Respondent was allegedly demanding double
the said amount of P21, 000.00, that is, a total of P42,
000.00. The Complainants rejected such an unfair,
unjust, iniquitous, unconscionable, immoral, usurious,
and unacceptable demand for P42, 000.00.

3.10. Please note that the Respondent’s demand for

P42, 000.00 as of 15 October 2014 or thereabout, in
relation to the original verbal loan of P15, 000.00
contracted by the herein Complainant XXX on 20
September 2014, would amount to a huge and unjust
interest of thirty-five percent (35%) for very short
period of twenty-five (25) days (i.e., 20 September
2014 to 15 October 2014). This was clearly usurious,
immoral, unacceptable, iniquitous, unconscionable,
and unjustified, considering that no interest was
formally agreed upon or stipulated when the verbal
loan for P15, 000.00 was consummated between the
Complainant XXX and the Respondent on 20
September 2014. The Respondent did not present to
the herein Complainants at that time and up to the
present time any credible documentary proof
identifying his anonymous Financier. Neither did the
Respondent present to the herein Complainants at
that time and up to the present time any
documentary proof of demand/collection, statement
of account, billing, letter, or any written request or
instruction from his anonymous Financier to prove the
allegation of the Respondent that his anonymous
Financier was indeed demanding P42, 000.00 at that
time.
3.11. The Complainants at that time demanded that
the Respondent the name, address and contact
details of the anonymous Financier so that the herein
Complainants could personally discuss and explain
his position to the Financier. But the Respondent
refused and continues to refuse to this very day to
give to the herein Complainants the name, address
and contact details of the anonymous Financier.

3.12. After the said telephone call of the Respondent to

the herein Complainant XXX made on 15 October
2014 or thereabout, the Respondent kept quiet for
two (2) months. Then sometime in December 2014 or
thereabout the Respondent again called up the
herein Complainant XXX alleging that the past-due
interest of the latter on the original principal loan of
P15,000.00 made on 20 September 2014 had already
escalated to P100,000.00 as of the date of his call in
December 2014. The Respondent alleged that he
had mortgaged his house to his anonymous Financier
to pay for the said unpaid interest of the herein
Complainant XXX. The herein Complainants,
doubting the sincerity and truthfulness of the
allegation of the Respondent, demanded the name,
address and contact details of the Financier so that
the herein Complainants could forthwith talk and
discuss the issue with the said Financier. They also
demanded copies of any documentary proof
justifying the claim of P100, 000.00 interest as of that
time (December 2014). But the Respondent failed
and refused and continues to fail and refuse to this
very day to provide the herein Complainants such
information and documentary proof/s.
3.13. On 7 October 2015 or thereabout the Respondent
again called up the herein Complainant XXX, saying
that the former was at that time waiting inside Xxx Xxx
I Subdivision near the home of the herein
Complainants, inside his van, and that the
Respondent wished to talk with the herein
Complainant XXX for a while about his loan. The
herein Complainant XXX agreed to meet with the
Respondent outside his home. When they met, the
Respondent asked the herein Complainant XXX to go
inside his van for a more private discussion. When the
herein Complainant XXX the van of the Respondent,
he was surprised to see a man who identified himself
as XXX XXX, who showed the Respondent a
government ID. XXX threatened the Respondent with
the following words:

“HOY, IKAW, LOKO KA HA! MAY UTANG KA PALA

NANG GANITO KALAKI KAY XXX. HINDI MO BA AKO
KILALA? xxx AKO NG ASSOCIATION NG XXX XXX.
SUMAMA KA SA AKIN SA BARANGAY. PAG HINDI KA
SUMAMA, PAPALABASIN KO KAYO SA XXX AT HINDI
NA KAYO PWEDE TUMIRA DITO.”

3.14. Although the herein Complainant XXX, being a xxx

national, has no perfect mastery of the Tagalog
language, he understood the context of the
threatening words of XXX based on his facial
expressions and hand movements and based on the
harassing presence of the Respondent. Despite the
fact that there was no pending formal Barangay
complaint against the herein Complainant XXX and
despite the fact that there was no official Barangay
summons issued to him at that time, he was forced by
 XXX and the Respondent to go with them to the
Barangay Hall of Barangay Xxx 5, Xxx Xxx City right
that very moment.

3.15. At the Barangay Hall, the herein Complainant XXX

told the Barangay officer, by the name of “Deputy
xxx ”, (a) That he had not received any formal
Barangay complaint or formal Barangay summons;
and (b) That the claim of the Respondent for P366,
000.00 was baseless, unfounded, untrue, false, and
fabricated.

3.16. The herein Complainant XXX, without the aid of an

interpreter, was forced by Barangay Deputy XXX,
XXX, and the Respondent to sign a page of the
Barangay logbook, which turned out later to be a
“KASUNDUAN”.

3.17. The herein Complainant XXX was misled by

Barangay Deputy XXX, XXX, and the Respondent that
the document was only a harmless record or minutes
of the Barangay meeting. The contents and the legal
effects of the said document were not explained and
interpreted to the herein Complainant XXX by
Barangay Deputy XXX or any Barangay Kagawad or
by the Barangay Secretary or by any Lupon Officer or
Member.

3.18. The herein Complainant XXX signed the

Kasunduan UNDER DURESS. He was MISLED by
Barangay Deputy XXX to sign it. He was
threatened/intimidated by XXX and the Respondent
to sign it. He did not understand its contents,
consequences, and legal effects because, as a
Japanese national, he has no mastery of English and
 Tagalog, although he could understand and speak
some simple conversational English and Tagalog
words. He was not assisted by an Interpreter or by a
lawyer of his choice. All he knew was that the said
document was a harmless minutes of meeting, as
represented to him by Barangay Deputy XXX, XXX
and the Respondent.

3.19. Later, in his criminal complaint for Estafa against

the herein Complainant XXX, the Respondent would
capitalize on the said KASUNDUAN as the sole basis
of his FINAL DEMAND LETTER to prove the alleged
financial liability of the Complainant XXX. The
Kasunduan was an entrapment document used by
the Respondent to document a verbal loan
agreement and to evade the degree of evidence
required by the Statutes of Frauds of the Civil Code.

3.20. Aside from the suspicious Kasunduan, the

Respondent has not presented any credible
document, such as, but not necessarily limited to, a
CONTRACT OF LOAN, a PROMISSORY NOTE, a
VOUCHER, a STATEMENT OF ACCOUNT, or a BILL
executed or signed by the Lender and the Borrower:
To prove the financial claim of the Respondent and
his anonymous Financier; To prove the veracity of
the computation/s of the usurious, unconscionable
and iniquitous interests of the herein Complainant
XXX; and To prove compliance by the Respondent
and his anonymous Financier with the mandatory
provisions of the TRUTH IN LENDING ACT in re: the
formal issuance by the Lender to the Borrower of a
FULL DISCLOSURE STATEMENT, containing the amount
of the principal loan, the stipulated interest rate, the
 stimulated penalties and surcharges, if any and other
covenants related to the agreed loan.

3.21. After a few days from 7 October 2015, the

Respondent made a series of calls to the herein
Complainant XXX, pestering the latter to pay his
alleged obligation. The Respondent alleged and
stated: That the payment should be made by the
herein Complainant XXX at the home of XXX, vice
president of the homeowners association of Xxx Xxx
Subdivision (who was not a party to the oral loan
transaction); That the Respondent would soon leave
for abroad; That his wife would soon return from
abroad; and That it would be a great problem on his
part if his wife would discover that he had mortgaged
his house (and, this time, allegedly including his van)
to his anonymous Financier to secure the alleged
obligation of the herein Complainant XXX.

3.22. Sometime in the latter part of October 2015 or

thereabout the Respondent visited the home of the
herein Complainants, accompanied by an
unidentified man whose appearance appeared to
be suspicious. The Respondent repeated his demand
to be paid, this time, in the total amount of P366,
000.00. The herein Complainants insisted that they
had already settled in full his original verbal loan of
P15, 000.00 with P6, 000.00 interest. They demanded
that the Respondent show proofs of the alleged
liability of the herein Complainant XXX and the
computations of the alleged past-due interests, either
in the form of a voucher or an official receipt or a
statement of account or a billing or a promissory note
or a contract of loan or any other credible document.
Ignoring the foregoing demand of the herein
 Complainants, the Respondent insisted that the
herein Complainants pay the total amount he was
claiming and that the same be paid by them at the
home of XXX. The Complainants were thus
constrained to tell the Respondent that it would be
better for him to file a court case to prove his claim
so that the truth would come out.

3.23. Please note that in the Barangay KASUNDUAN,

dated 7 October 2015, the alleged financial
obligation of the herein Complainant XXX, according
to the Respondent, was P366, 000.00. It contradicts
the Final Demand Letter, dated 12 November 2015, of
the Respondent, which claimed the total amount of
P326, 000.00 - or a huge and unexplained difference
of P40, 000.00.

3.24. On 26 November 2015 the herein Complainant

confronted XXX at his home in Xxx Xxx Subdivision.
She brought along with her, as her
mediators/witnesses, the Spouses XXX AND XXX. Xxx
was a past president of the homeowners association
of the subdivision. During the said confrontation, the
Respondent was mysteriously present inside the home
of XXX. In that confrontation, herein Complainant XXX
told XXX: That the herein Complainants have been
residents/tenants of the subdivision for seven (7)
years; That as the vice president of the homeowners
association vested with the legal duty to serve the
common good of the homeowners/tenants of the
subdivision, XXX should have taken steps to protect
the herein Complainants as residents/tenants of the
subdivision (i.e., as his constituents in the subdivision)
against the baseless and unfounded claim of the
 Respondent; That at the very least XXX should have
first consulted and heard the side of the herein
Complainants when the Respondent first sought his
assistance to collect from the herein Complainant
XXX; and that he should not have believed outright,
hook line and sinker, the said claim of the
Respondent without first giving the herein
Complainants an opportunity to be heard; That the
act of XXX of coercively bringing the herein
Complainant XXX to the Barangay Hall on 7 October
2015, without the assistance of the herein
Complainant XXX and based solely on the personal
request of the Respondent -- and without the prior
filing by the Respondent of a formal Barangay
complaint and without the prior issuance by the
Barangay Secretary of a formal Barangay summons
to the Complainant -- was an unjust, unfair, and
illegal act of harassment, intimidation, and unjust
vexation.

3.25. To put an end to abusive and pestering collection

behavior of the Respondent -- and solely to buy
peace, without admitting any liability on the part of
the herein Complainants and without admitting the
validity of the claim of the Respondent in the amount
of P366, 000.00 -- the herein Complainants paid the
Respondent an additional amount of P47, 000.00 on
October 15, 2015, via a deposit to the bank account
of the Respondent, hoping that such an amount
would finally end the baseless claim and collection
pestering/harassment of the Respondent. But it was
not so. The Respondent continues to insist on his
claim of P366, 000.00 by filing a harassment case for
Estafa.
3.26. The herein Complainants believes that the
Complainant is using the Criminal Justice System as
his own coercive COLLECTION AGENCY. It is the
hope and prayer of the herein Complainants that this
Honorable Office would resist the malicious move of
the Complainant to use, mislead, and exploit it as his
pro bono personal COLLECTION AGENCY.

3.27. On 26 November 2015, the herein Complainant

XXX filed a complaint with Barangay Xxx against the
Complainant and XXX. During the Barangay
conciliation XXX apologized to her for his
behavior. The herein affiant accepted his apology,
with the hope that XXX would be more discerning as
a community leader in the future.

3.28. On January 18, 2016 at 7:00 PM, the Subpoena of

this Honorable Office in re: the Estafa case filed by
the Respondent was delivered by the process server
of this Honorable Office at the new home address of
the Respondent at Xxx Xxx Subdivision. (It was
originally addressed to the old home address of the
herein Complainants in the same subdivision). The
herein Complainants was constrained to retain the
legal services of the LASERNA CUEVA-MERCADER LAW
OFFICES, Xxx Xxx City, to defend their legal and
constitutional rights, in the interest of truth and justice;
to disprove the false, fabricated, baseless,
unfounded, and malicious claim of the Complainant;
and to file the necessary criminal and/or civil
counter-charges against the Respondent.

4. CONTRADICTIONS AND INCONSISTENCIES IN THE

DOCUMENTS OF THE RESPONDENT. - Please note the
internal contradictions and inadequacies among the
 documents submitted by the Respondent in the
Estafa case.

AS TO THE AMOUNT OF THE ALLEGED CLAIM:

(a) In his Sworn Statement, dated 14 December

2015, given before the Xxx City Police Station, the
Respondent claims P326,000.00;

(b) In the Barangay Kasunduan, 7 October 2015, he

claims P366,000.00;

(c) In the Final Demand Letter, dated 12

November 2015, he claims P326,000.00;

(d) In the Special Power of Attorney (SPA), dated 14

December 2015, he claims P326,000.00;

(e) Please note that in all of the foregoing

allegations no VOUCHERS, OFFICIAL RECEIPTS,
STATEMENTS OF ACCOUINTS, BILLS, PROMISSORY
NOTES, CONTRACTS OF LOAN, and/or DISCLOSURE
STATEMENTS were presented by the Respondent to
prove his claim.

AS TO THE PURPOSE OF THE ALLEGED LOAN OF THE

HEREIN COMPLAINANT XXX.

(a) In his Sworn Statement, dated 14 December

2015, given before the Xxx Xxx City Police Station, the
 Respondent alleged that he and the Respondent
agreed to go into the business of money lending. (Q
and A No. 6).

(b) In his Special Power of Attorney (SPA), dated 14

December 2015, he alleged that his claim was based
on alleged “Ticket Purchase”. (Par. 1, SPA).

(c) Please note that the Respondent has not

presented any proof of his alleged partnership
agreement or business agreement with the herein
Complainant XXX to establish a money lending
business referred to in Q and A No. 6 of his Sworn
Statement, dated 14 December 2015, e.g.,
AGREEMENT/CONTRACT, MEMORANDUM OF
UNDERSTANDING, ARTICLES OF PARTNERSHIP,
AFFIDAVIT, UNDERTAKING, DEED, LETTERS AND OTHER
COMMUNICATIONS, and the like.

(d) Please note, too, that the Respondent has not

presented any proof of the alleged “Ticket Purchase”
of the herein Complainant XXX, referred to in Par. 1 of
his SPA, dated 14 December 2015, e.g., VOUCHERS,
PLANE TICKETS, BILLS, STATEMENTS OF ACCOUNT,
UNDERTAKINGS, DEEDS, LETTERS AND OTHER
COMMUNICATIONS, and the like.

5. The herein Complainants hereby submit to this

Honorable Office the following additional documents
to support their instant complaint for Perjury:

(a) Annex “B” – xxx Cash Deposit Slip

#001281045029, dated 30 September 2014, in the
amount of P21, 000.00 paid to the bank account of
 the Respondent - to prove the full payment by the
Complainants of their oral loan dated 20 September
2014, broken down as follows: The agreed principal
loan of P15, 000.00; and The unstipulated interest of
P6, 000.oo demanded by the Respondent.

(b) Annex “C” and “C-1” – Barangay Blotter, dated

26 November 2015, re: the Barangay complaint of
the herein Complainant XXX against the unjust and
coercive acts of harassment of the Respondent and
XXX XXX.

Note:

Due to lack of material time, the herein

Complainants cannot submit as an annex of this
pleading at this time a copy of the xxx Cash Deposit
Slip, dated 15 October 2015, in the amount of P47,
000.00 to prove that the herein Complainants had
deposited the said amount to the bank account of
the Respondent to buy peace, without admitting any
liability on the part of the herein Complainant XXX
and without admitting the validity of the claim of the
Respondent. The herein Complainants will attempt
this week to secure from the Bank a formal
Certification of its Branch Manager to corroborate
the foregoing fact. The herein Complainants reserve
the right to present the said bank certification as an
annex to their future Reply-Affidavit. The said Cash
Deposit Slip was misplaced or thrown away by the
housemaid of the herein Complainants, together with
other personal papers, when their family recently
moved to their new home address in the same
subdivision. The housemaid mistakenly thought that
those papers were trash and unnecessary.
 At any rate, please note that the Complaint admits in
Q and A No. 7 of his Sworn Statement, dated 14
December 2015, that he indeed RECEIVED from the
Respondent the said amount of P47,000.00.

6. The herein Complainant XXX has REVOKED the

dubious, unfair, invalid, and misleading BARANGAY
KASUNDUAN, dated 7 October 2015 (written in
Tagalog, which is not the mother language of the
Complainant xxx), the reason being that he was
forced to sign the same UNDER DURESS, UNDER THE
MISLEADING AND FALSE REPRESENTATION of
Barangay Deputy Xxx, in cahoots with XXX and the
Respondent, that the document was merely a
harmless record/minutes of the their Barangay
meeting, and WITHOUT A FULL, INTELLIGENT, AND
VOLUNTARY KNOWLEDGE, CONSENT AND
UNDERSTANDING OF THE LEGAL EFFECTS AND
CONSEQUENCES THEREOF on his part.

7. ARTICLE 183 of the Revised Penal Code provides:

“Article 183. - False testimony in other cases and

PERJURY in solemn affirmation. — The penalty of
arresto mayor in its maximum period to prision
correccional in its minimum period shall be imposed
upon any person, who, knowingly makes untruthful
statements and not being included in the provisions
of the next preceding articles, shall testify under oath,
or make an affidavit, upon any material matter
before a competent person authorized to administer
an oath in cases in which the law so requires.
Any person who, in case of a solemn affirmation
made in lieu of an oath, shall commit any of the
falsehoods mentioned in this and the three
preceding articles of this section, shall suffer the
respective penalties provided therein.”

WHEREFORE, it is respectfully prayed that the

Respondent be indicted for PERJURY under Art. 183 of
the Rev. Penal Code and/or such other penal laws as
may be justified/warranted by the facts of this case.

FURTHER, the herein Complainants pray for such

and other reliefs as may be deemed just and
equitable in the premises.

Xxx Xxx City, 27 January 2016.

XXX XXX
Complainant
xxx St.
Xxx Subd.
Xxx City

XXX XXX
Complainant
Xxx St.
Xxx Subd.
Xxx City
 SUBSCRIBED and sworn to before me in Xxx Xxx
City on ___ January 2016.

Administering Assistant City

Prosecutor