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IN THE COURT OF THE JUNIOR CIVIL JUDGE: MADANAPALLE

O.S.NO: /2012

Plaintiff : Peravali Manohara

Defendant : Kalisam Pullaiah

PLAINT FILED ON BEHALF OF THEPLAINTIFF UNDER ORDER VII, RULE 1

R/W. SECTION 26: C.P.C.1. Plaintiff : Peravali Manohara, S/o.Peravali Gopal, aged about 35 years,

Hindu, residing at D.NO:9/204,Kammaveedhi, 2 nd lane,

Madanapalle.

The address of the Plaintiff is as statedabove and also care of Sri B. Bhujanga Rao, B.Sc,LLB,M.Venkatappa, BA,LLB,B. Chandra SekharRao,BA,LLB,M.N.Nagalakshmi,BAL,BL,G.Manohara, BA,LLB,Advocates, Madanapalle.

2. Defendant : Kalisam Pullaiah, S/o.

Thippaiah, aged about 60 years, Hindu,residing at Tekulapalem, H/o.Vempalle, Madanapalle Mandal

The address of the Defendant is asstated above for all purposes of service

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of process, summons, etc., issued fromthis Honble court.

3. The Plaintiff humbly submits that on 01-

11-2009, the Defendant borrowed a sum

of Rs.10,000/- (Rs. Ten thousands only)

from the Plaintiff for his legal necessities

and justifiable causes, agreeing to repaythe same with interest @24%p.a, on

demand either to the Plaintiff or to his

order and in evidence thereof, the

Defendant executed the suit pronote in

favour of the Plaintiff on the even date.

4. Inspite of repeated demands made by the

Plaintiff, the Defendant has been

postponing to discharge the said debt

along-with interest on some pretext or theother and the entire debt is still due. The

Plaintiff also caused a legal notice dt:23-

04-2012 to the Defendant calling him

upon to discharge the suit debt and theDefendant, having received the said legal

notice, neither sent any reply, nor paid the

amount, and thereby, virtually admitted

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the contents of the said legal notice.

Since the Defendant has been

intentionally evading to discharge thePlaintiffs debt, he is constrained to file

this suit.

5. The cause of action for this suit arose on

01-11-2009, when the Defendant

borrowed Rs.10,000/- from the Plaintiff

and executed the suit pronote, and when

the Defendant failed to discharge the said

debt inspite of repeated demands and

inspite of issuance of legal notice dt:23-

04-2012 and at Madanapalle, where the

suit transaction took place within the

jurisdiction of this Honble court.

6. Particulars of valuation:

Principle amount under suit pronote dt: 01-

11-2009: Rs. 10,000/-

Interest on Rs.10,000/- @24%p.a.,

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from 01-11-2009 to 10-06-2012 :

Rs. 6,260/-

Total :

Rs.16,260/-

The value of the suit for purpose of court

fee and Jurisdiction is Rs16,260/- and a

court fee of Rs. /- is paid under S.20

of A.P.C.F.Act.

7. PRAYER: It is therefore most humbly

prayed that the Honble court may be

pleased to Pass a Decree and Judgment

in favour of the Plaintiff and against the

Defendant:

a) By directing the Defendant to pay the

suit amount of Rs.16,260/- to the

Plaintiff with interest @24%p.a, from

the date of suit till realization;

b) Award the costs of the suit; and

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c) Pass such other or further reliefs as

this Honble court deems fit and proper

under the Circumstances of the case,

in the interest of justice.

Counsel for the Plaintiff

Plaintiff

Verification The facts stated above are all read over

and explained to me in Telugu andadmitted herein to be true and correct tothe best of my knowledge, belief andinformation.

Madanapalle,Plaintiff

Dt: 11-06-2012List of Documents:

1. 01-11-2009 : Original suit pronoteexecuted by the Defendant in favour

of the Plaintiff;2. : Xerox copy of Document no:1.3. 23-04-2012 : Office copy of legalnotice issued by the Plaintiff to the

Defendant;4. : Postal Acknowledgement card.

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be read as part and parcel of this Affidavitfor all material purposes.

3. I submit that on 01-11-2009, the

Defendant borrowed a sum of Rs.10,000/-

(Rs. Ten thousands only) from me for his

legal necessities and justifiable causes,

agreeing to repay the same with interest

@24%p.a, on demand either to me or tomy order and in evidence thereof, the

Defendant executed the suit pronote in

my favour on the even date.

4. Inspite of repeated demands made by me,

the Defendant has been postponing to

discharge the said debt along-with interest

on some pretext or the other and the

entire debt is still due. I also caused a

legal notice dt;23-04-2012 to the

Defendant calling upon him to discharge

my debt, and the Defendant, for which,

also the Defendant has not come forward

to discharge my debt. Since theDefendant has been intentionally evading

to discharge my debt, I am constrained to

file this suit.

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5. It is therefore most humbly prayed thatthe Honble court may be pleased to Passa Decree and Judgment in my favour andagainst the Defendant by directing theDefendant to pay the suit amount of Rs.16,260/- to me with interest @24%p.a,from the date of suit till realization; Awardthe costs of the suit; and Pass such otheror further reliefs as this Honble courtdeems fit and proper under theCircumstances of the case, in the interestof justice.

Deponent

Solemnly affirmed and signed before me

on 11-06-2012 at Madanapalle.

Advocate

IN THE COURT OF THE JUNIOR CIVIL JUDGE: MADANAPALLE

O.S.NO: /2012

Plaintiff : Peravali Manohara

Defendant : Kalisam Pullaiah

DUPLICATE PLAINT FILED ON BEHALF OFTHE PLAINTIFF UNDER ORDER XVIII,

RULE 4: C.P.C.1. Plaintiff : Peravali Manohara, S/o.Peravali Gopal, aged about 35 years,

Hindu, residing at D.NO:9/204,Kammaveedhi, 2 nd lane,Madanapalle.

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The address of the Plaintiff is as statedabove and also care of Sri B. Bhujanga Rao, B.Sc,LLB,M.Venkatappa, BA,LLB,B. Chandra SekharRao,BA,LLB,M.N.Nagalakshmi,BAL,BL,G.Manohara, BA,LLB,Advocates, Madanapalle.

2. Defendant : Kalisam Pullaiah, S/o. Thippaiah, aged about 60 years, Hindu,

residing at Tekulapalem, H/o.Vempalle, Madanapalle Mandal

The address of the Defendant is as

stated above for all purposes of serviceof process, summons, etc., issued fromthis Honble court.

3. The Plaintiff humbly submits that on 01-

11-2009, the Defendant borrowed a sum

of Rs.10,000/- (Rs. Ten thousands only)

from the Plaintiff for his legal necessities

and justifiable causes, agreeing to repay

the same with interest @24%p.a, on

demand either to the Plaintiff or to hisorder and in evidence thereof, the

Defendant executed the suit pronote in

favour of the Plaintiff on the even date.

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4. Inspite of repeated demands made by the

Plaintiff, the Defendant has been

postponing to discharge the said debtalong-with interest on some pretext or the

other and the entire debt is still due. The

Plaintiff also caused a legal notice dt:23-

04-2012 to the Defendant calling him

upon to discharge the suit debt and the

Defendant, having received the said legal

notice, neither sent any reply, nor paid the

amount, and thereby, virtually admitted

the contents of the said legal notice.

Since the Defendant has been

intentionally evading to discharge the

Plaintiffs debt, he is constrained to file

this suit.5. The cause of action for this suit arose on

01-11-2009, when the Defendant

borrowed Rs.10,000/- from the Plaintiff

and executed the suit pronote, and when

the Defendant failed to discharge the said

debt inspite of repeated demands and

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inspite of issuance of legal notice dt:23-

04-2012 and at Madanapalle, where the

suit transaction took place within the

jurisdiction of this Honble court.

6. Particulars of valuation:

Principle amount under suit pronote dt: 01-

11-2009: Rs. 10,000/-

Interest on Rs.10,000/- @24%p.a.,

from 01-11-2009 to 10-06-2012 :

Rs. 6,260/-

Total :

Rs.16,260/-

The value of the suit for purpose of court

fee and Jurisdiction is Rs16,260/- and a

court fee of Rs. /- is paid under S.20

of A.P.C.F.Act.

7. PRAYER: It is therefore most humbly

prayed that the Honble court may be

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pleased to Pass a Decree and Judgment

in favour of the Plaintiff and against the

Defendant:

a) By directing the Defendant to pay the

suit amount of Rs.16,260/- to the

Plaintiff with interest @24%p.a, from

the date of suit till realization;

b) Award the costs of the suit; and

c) Pass such other or further reliefs as

this Honble court deems fit and proper

under the Circumstances of the case,

in the interest of justice.

Counsel for the Plaintiff

Plaintiff

Verification The facts stated above are all read overand explained to me in Telugu andadmitted herein to be true and correct to

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the best of my knowledge, belief andinformation.

Madanapalle,Plaintiff

Dt: 11-06-2012List of Documents:

1. 01-11-2009 : Original suit pronoteexecuted by the Defendant in favour

of the Plaintiff;2. : Xerox copy of Document no:1.3. 23-04-2012 : Office copy of legalnotice issued by the Plaintiff to the

Defendant;

4. : Postal Acknowledgement card.

Counsel for the Plaintiff

IN THE COURT OF THE JUNIOR CIVIL JUDGE: MADANAPALLE

O.S.NO: /2012

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Plaintiff : Peravali ManoharaDefendant : Kalisam Pullaiah

Affidavit of the Plaintiff I, Peravali Manohara, S/o. PeravaliGopal, aged about 35 years, Hindu,residing at D.NO:9/204, Kammaveedhi,2 nd lane, Madanapalle. , do herebysolemnly affirm and state as follows:1. I am the Plaintiff in the above suit andDeponent herein.

2. I submit that I have filed the above suit forrealization of the suit amount from theDefendant along-with interest and costsbasing on the suit pronote dt: 01-11-2009 and the Plaint pleadings may kindly

be read as part and parcel of this Affidavitfor all material purposes.

3. I further submit that the Defendant,

having borrowed the amount from me

long back in the year, 2009, has been

intentionally evading to discharge my debt

and so far, he has not paid even a copper

coin to me. The Defendant is also

indebted to several other creditors like me

and he is the rightful owner of the petition

schedule Property. In order to disable his

creditors like me, the Defendant has been

making hectic efforts to alienate the

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petition Schedule Property and serious

negotiations have been going on in this

regard. Except the Schedule Property, theDefendant has no other Property and if the

Defendant succeeds in his unlawful

attempts, I will not be in a position to

enjoy the fruits of the decree that may be

passed in my favour. Thus, to protect my

interest to realize the amount from the

Defendant, it is just and essential to

attach the Schedule Property. Hence, this

petition.

4. It is therefore most humbly prayed thatthe Hon'ble court may be pleased toATTACH the Schedule Property BEFORE

JUDGMENT, for the above submittedreasons, in the interest of justice. Or else, Iwill be put to serious loss and greathardship.

Deponent

Solemnly affirmed and signed before me

on 11-06-2012 at Madanapalle

Advocate

IN THE COURT OF THE JUNIOR CIVIL JUDGE: MADANAPALLE

I.A.NO: /2012

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O.S.NO: /2012

Petitioner/Plaintiff : Peravali Manohara, S/o. PeravaliGopal, aged about 35 years,

Hindu, residing at D.NO:9/204,Kammaveedhi, 2 nd lane,Madanapalle.

Respondent/Defendant : Kalisam Pullaiah, S/o.

Thippaiah, aged about 60 years, Hindu,residing at Tekulapalem, H/o.

Vempalle, Madanapalle Mandal

PETITION FILED ON BEHALF OF THEPETITIONER/ PLAINTIFF UNDER ORDER

38, RULE 5 R/W. S.151, 94(e): C.P.C. That for the reasons stated in the enclosedaffidavit, it is therefore most humblyprayed that the Hon'ble court may bepleased to ATTACH the Schedule PropertyBEFORE JUDGMENT, in the interest of

justice. Or else, the Petitioner will be putto serious loss and great hardship.

Madanapalle, counsel forthe Petitioner/ Plaintiff

Dt: 11-06-2012

SCHEDULEChittoor DistrictMadanapalle sub-

districtVempalle Revenue villageLanded

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Property bearing1. Sircar Dry S.NO:1308 Ext.Ac.3-

40 cents2. Sircar Dry S.NO:1490 Ext.Ac.5-

50 cents3. Sircar Dry S.NO:1333 Ext.Ac.-3-

73 cents

With all fruit bearing trees, watersources, etc.,.

Counsel for the Petitioner/ Plaintiff

IN THE COURT OF THE 1ST ADDITIONAL JUNIOR CIVIL JUDGE: MADANAPALLEO.S.NO: 230/2012

Plaintiff : Peravali Manohara

Defendant : Kalisam PullaiahCHIEF-EXAMINATION AFFIDAVIT OF P.W.-1 FILED UNDER ORDER 18, RULE 1 : C.P.C.I, Peravali Manohara, S/o. Peravali Gopal, aged about 35 years, Hindu, residingat D.NO:9/204, Kammaveedhi, 2 nd lane, Madanapalle, do hereby solemnly affirmand state as follows:1. I am the Plaintiff in the above suit and Deponent herein.

2. I submit that on 01-11-2009, the Defendant borrowed a sum of Rs.10,000/-

(Rs. Ten thousands only) from me for his legal necessities and justifiable

causes, agreeing to repay the same with interest @24%p.a, on demand either to

me or to my order and in evidence thereof, the Defendant executed the suit

pronote in my favour on the even date.

3. Inspite of repeated demands made by me, the Defendant has been postponing

to discharge the said debt along-with interest on some pretext or the other andthe entire debt is still due. I also caused a legal notice dt;23-04-2012 to the

Defendant calling upon him to discharge my debt, and the Defendant, for

which, also the Defendant has not come forward to discharge my debt. Since

the Defendant has been intentionally evading to discharge my debt, I am

constrained to file this suit.

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4. It is therefore most humbly prayed that the Honble court may be pleased to

Pass a Decree and Judgment in my favour and against the Defendant by

directing the Defendant to pay the suit amount of Rs.16,260/- to me with

interest @24%p.a, from the date of suit till realization; Award the costs of the

suit; and Pass such other or further reliefs as this Honble court deems fit and

proper under the Circumstances of the case, in the interest of justice.

Deponent

Solemnly affirmed and signed before me on 09-04-2013 at Madanapalle.

Advocate

List of Documents sought to be marked as Exhibits:

Ex.A-1: 01-11-2009 : Original suit pronote executed by the Defendant in favourof the Plaintiff;

Ex.A-2: 23-04-2012 : Office copy of legal notice issued by the Plaintiff to theDefendant;

Ex.A-3: : Postal Acknowledgement card.

Counsel for the Plaintiff

IN THE COURT OF THE 1ST ADDITIONAL JUNIOR CIVIL JUDGE: MADANAPALLE

O.S.NO: 230/2012Plaintiff : Peravali Manohara

Defendant : Kalisam PullaiahCHIEF-EXAMINATION AFFIDAVIT OF P.W.-2 FILED UNDER ORDER 18, RULE 1 : C.P.C.I, Valligatla Ramakrishna, S/o. Venkatramana, aged about 32 years, Hindu, Mason,residing at Malepadu village an post, do hereby solemnly affirm and state asfollows:1. I am the Plaintiff in the above suit and Deponent herein.

2. I submit that on 01-11-2009, the Defendant borrowed a sum of Rs.10,000/-(Rs. Ten thousands only) from the Plaintiff for his legal necessities and

justifiable causes, agreeing to repay the same with interest @24%p.a, on

demand either to the Plaintiff or to his order and in evidence thereof, the

Defendant executed the suit pronote in favour of the Plaintiff on the even

date.

3. On the date of execution, i.e., on 01-11-2009, I accompanied the Defendant at

his request to the Plaintiffs house and at the time of execution, myself, the

Plaintiff, the Defendant were present. In my presence, the Plaintiff lent the

sum of Rs.10,000/- to the Defendant and the Defendant after counting the

amount, himself scribed the suit pronote under Ex.A-1 and subscribed his

signatures across the two Revenue stamps and beneathe the same in telugu.

He also subscribed his signature as scribe in the scribe column. Thereafter, I

signed as attestor in Ex.A-1. Thus, the suit transaction took place in my

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presence and the Defendant became indebted to the Plaintiff to the tune of

Rs.10,000/-.

Deponent

Solemnly affirmed and signed before me on 09-07-2013 at Madanapalle

Advocate