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Memorandum Template

This memorandum was submitted by the plaintiff-respondent's counsel in a civil case regarding ejectment. It outlines the parties to the case, with the plaintiff residing in Manila and the defendant residing elsewhere. It notes that a factual and procedural background will be provided, and lists the issues of the case to be argued. The memorandum requests that the Supreme Court deny the defendant-petitioner's request for an injunction and dismiss the case as unmeritorious, while granting any other just relief. It was submitted on April 8, 2011 in Makati City.

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377 views2 pages

Memorandum Template

This memorandum was submitted by the plaintiff-respondent's counsel in a civil case regarding ejectment. It outlines the parties to the case, with the plaintiff residing in Manila and the defendant residing elsewhere. It notes that a factual and procedural background will be provided, and lists the issues of the case to be argued. The memorandum requests that the Supreme Court deny the defendant-petitioner's request for an injunction and dismiss the case as unmeritorious, while granting any other just relief. It was submitted on April 8, 2011 in Makati City.

Uploaded by

Wanderer
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOC, PDF, TXT or read online on Scribd

Republic of the Philippines

SUPREME COURT
Manila City

______________________,
Defendant-Petitioner,

-versus- CIVIL CASE NO. __________


For: Ejectment

____________________,
Plaintiff-Respondent.
x-------------------------------------------------------------------------x

MEMORANDUM

COME NOW PLAINTIFF-RESPONDENT, through the undersigned counsel, unto


this Honorable Supreme Court most respectfully submit and present this Memorandum in the
above-titled case and aver that:

THE PARTIES

1. Plaintiff-Respondent _______ is of legal age, single, and residing at_____________,


where she may be served with legal processes and notices issued by this Honorable Court;

2. Defendant-Petitioner ________ is of legal age and residing at _____________, and may


be served with legal processes and other judicial notices thereto.

I. PROCEDURAL BACKGROUND

1. AVERMENTS ON TIMELINESS OR COMPLIANCE WITH THE ORDER OF THE


COURT

Hence, the filing of the instant Memorandum.

II. FACTUAL BACKGROUND

2. AVERMENTS OF RELEVANT FACTS

III. ISSUES OF THE CASE


A.) WHETHER OR NOT

IV. ARGUMENTS

V. DISCUSSIONS

DISCUSSIONS OF EACH ARGUMENTS

PRAYER

WHEREFORE, premise considered, it respectfully prayed for that this Honorable


Supreme Court that Defendant-Petitioner’s prayer for writ of injunction be DENIED for having
no cause of action and the petition DISMISSED for being clearly unmeritorious.

Other just and equitable relief under the foregoing are likewise being prayed for.

Respectfully submitted.

Makati City for Manila City, Philippines. April 8, 2011.

____LAW FIRM___
Counsel for Plaintiff-Respondent
ADDRESS

By:

ATTY. __________
IBP Lifetime No.
PTR No.
Roll of Attorney No.
MCLE Compliance No.

Copy Furnished:

ATTY. ___________________
ADDRESS

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