Complaint-Specific-Performance.docx - Republic of the Philippines REGIONAL TRIAL COURT Eleventh Judicial Region Branch 16 Davao City JIMMEY C KIMMEL

Complaint-Specific-Performance.docx - Republic of the...

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Republic of the Philippines REGIONAL TRIAL COURT Eleventh Judicial Region Branch 16, Davao City JIMMEY C. KIMMEL Plaintiff, - versus - Civil Case No. Q-23516 For: Specific Performance with Damages KAREN P. KARPENTERO Defendant, X - - - - - - - - - - - - - - - - - - - - - X COMPLAINT COMES NOW, the Plaintiff by the undersigned counsel unto the Honorable Court respectfully alleges; 1. Plaintiff JIMMEY C. KIMMEY is of legal age, Filipino, with residence and postal address at Lot 5, Blk. 45, Phase 7-A, Bria Homes, Cagayan de Oro City, where he may be served notices and other court processes; 2. Defendant KAREN P. KARPENTERO is of legal age, Filipino, with residence and postal address at Phase 10, Kasilak Street, Country Homes, Cabantian, Davao City where she may be served notices and other court processes; 3. That on December 27, 2019 the herein Defendant posted online through social media, in specifically, that he was selling his car, a 2019 model Nissan Juke, subject to negotiations. Attached herewith is the photocopy of the post by the Defendant marked as Annex “A”; 4. That herein Plaintiff communicated with the Defendant through the said social media site his interest to buy the car. And on the same day, Plaintiff and
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