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Complaint Statement
"I need a Complaint Statement for filing in Manila Regional Trial Court against ABC Corporation for breach of a software development contract signed on January 15, 2025, seeking damages of 5 million Philippine Pesos and specific performance of contract obligations."
1. Caption: Contains the court name, parties' names, case number (if assigned), and type of pleading
2. Parties: Detailed information about the plaintiff(s) and defendant(s), including full names, addresses, and capacities
3. Jurisdiction and Venue: Statement establishing the court's jurisdiction and proper venue for the case
4. Material Facts: Chronological presentation of relevant facts that form the basis of the complaint
5. Causes of Action: Legal theories and specific violations or breaches that entitle the plaintiff to relief
6. Relief Sought: Specific remedies requested from the court
7. Verification: Sworn statement attesting to the truth of the allegations
8. Certification Against Forum Shopping: Mandatory certification that no similar action has been filed in other courts
1. Preliminary Statement: Brief overview of the case nature - used in complex cases to provide initial context
2. Legal Authorities: Detailed citations of relevant laws and jurisprudence - included when legal issues are complex or novel
3. Demand for Jury Trial: If applicable under specific circumstances where jury trial is allowed
4. Prayer for Preliminary Injunction/TRO: Used when immediate court intervention is needed to prevent irreparable harm
5. Request for Alternative Dispute Resolution: When parties are open to mediation or other forms of ADR
6. Additional Verification by Counsel: When the complaint is signed by counsel rather than the plaintiff
1. Annexes of Documentary Evidence: Copies of relevant documents supporting the allegations in the complaint
2. Secretary's Certificate: For corporate plaintiffs, authorizing the filing of the complaint
3. Special Power of Attorney: When complaint is filed by a representative
4. Demand Letters and Correspondence: Prior communications between parties relevant to the case
5. Photographs and Physical Evidence: Visual documentation of damages or incidents related to the complaint
6. Expert Reports: Technical or professional assessments supporting the claims
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