This document outlines four causes of action in a legal complaint. The second cause of action argues that the defendants' fraudulent registration of a property caused the plaintiff mental anguish and seeks moral damages. The third cause of action argues the fraudulent registration was wanton and seeks exemplary damages. The fourth cause of action argues the plaintiff incurred legal fees to protect their rights and seeks payment of attorney's fees and litigation expenses. The document requests judgement and damages under each cause of action.
This document outlines four causes of action in a legal complaint. The second cause of action argues that the defendants' fraudulent registration of a property caused the plaintiff mental anguish and seeks moral damages. The third cause of action argues the fraudulent registration was wanton and seeks exemplary damages. The fourth cause of action argues the plaintiff incurred legal fees to protect their rights and seeks payment of attorney's fees and litigation expenses. The document requests judgement and damages under each cause of action.
This document outlines four causes of action in a legal complaint. The second cause of action argues that the defendants' fraudulent registration of a property caused the plaintiff mental anguish and seeks moral damages. The third cause of action argues the fraudulent registration was wanton and seeks exemplary damages. The fourth cause of action argues the plaintiff incurred legal fees to protect their rights and seeks payment of attorney's fees and litigation expenses. The document requests judgement and damages under each cause of action.
This document outlines four causes of action in a legal complaint. The second cause of action argues that the defendants' fraudulent registration of a property caused the plaintiff mental anguish and seeks moral damages. The third cause of action argues the fraudulent registration was wanton and seeks exemplary damages. The fourth cause of action argues the plaintiff incurred legal fees to protect their rights and seeks payment of attorney's fees and litigation expenses. The document requests judgement and damages under each cause of action.
Download as DOCX, PDF, TXT or read online from Scribd
Download as docx, pdf, or txt
You are on page 1/ 2
IV
SECOND CAUSE OF ACTION
(Payment of Moral Damages)
1) The foregoing paragraphs are repleaded herein by way of
reference.
2) Defendants' wanton, fraudulent, reckless, oppressive and
malevolent acts and omissions, particularly in illegally, unlawfully and fraudulent registration of the subject property under the names of Benjamin Bautista and Jaime Sargote, has caused the Plaintiff to experience mental anguish, moral shock and sleepless nights.
3) Consequently, Defendants should be ordered to pay Plaintiff the
amount of ____________________________ as and for moral damages or in such amount as the Honorable Court may find just and reasonable.
V THIRD CAUSE OF ACTION (Payment of Exemplary Damages)
4) The foregoing paragraphs are repleaded herein by way of
reference.
5) By fraudulently registering the subject property in the name of
Benjamin Bautista and Jaime Sargote, Defendants acted in a wanton, fraudulent, reckless, oppressive, or malevolent manner.
6) Consequently, by way of example or correction for the public good,
Defendants should be ordered to pay Plainitff at least ____________________________ as exemplary damages.
VI FOURTH CAUSE OF ACTION (Payment of Attorney's Fees and Litigation Expenses)
7) The foregoing paragraphs are repleaded herein by way of
reference.
8) To protect his rights and interests and to seek redress for his grievance against Defendants, Plaintiff was compelled to engage the services of counsel for a fee and incur expenses for litigation. 9) Thus, Defendants should be ordered to pay the Plaintiff attorney’s fees in the amount of ____________________________ as acceptance fees, ____________________________ per hearing as appearance fees and ____________________________ per pleading.
PRAYER
WHEREFORE, premises considered, Plaintiff most respectfully prays
that a Judgment be issued in his favor and against the Defendants as follows:
a. Under the first Cause of Action, declaring Plaintiff as the true,
absolute and lawful owner of the subject property and ordering Defendant to reconvey to him the Subject Property.
b. Ordering the Registry of Deeds of lsabela to cancel the title under
the name of the Defendants and directing it to issue a new one under the name of the Plaintiff, as a consequence of the reconveyance.
c. Under the Second Cause of action, ordering Defendants to pay
____________________________ as and for moral damages;
d. Under the Third Cause of Action, ordering Defendants to pay
____________________________ as exemplary damages;
e. Under the Fourth Cause of Action, ordering Defendants to pay the
amount of ____________________________as acceptance fees, ____________________________ per hearing as appearance fees and ____________________________ per pleading, motion and judicial affidavit.
Other just and equitable reliefs undet the circumstances arc also prayed for.
