Republic of the Philippines

REGIONAL TRIAL COURT

FIRST JUDICIAL REGION
Branch 8
Baguio City

TL REALTY CORPORATION
Plaintiff,
Civil Case No. 0168
-versus - For: Collection of Sum of
Money

LEONARDO RAMOS,
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 August 3 to December 2009, 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.
 PRAYER

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 4th day of February 2011.

ATTY. DONNA K. NGOSLAB

Attorney for the Defendant
2/F BPI Bldg, Session Road,
Baguio City
PTR NO. 5562365; 01-08-11
IBP NO. 785623; Lifetime
ROLL NO. 43860; 05-06-07
MCLE Compliance No. III - 0003896

Copy Furnished:

ATTY. MARIA REMEDIOS L. BELLO

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.