1. I am handing you a piece of paper, do you recognize what it is?

[How did you acquire knowledge as to the piece of paper I have shown you?]

2. This is executed between SWIM and Shopsisters, correct?

3. When the outright agreement made by SWIM was agreed upon together with the Shopsisters,
what are the terms regarding payment? (45 days isasagot niya from the date of the contract) [NOTE:
misleading to kasi papalabasin natin na sila may gawa ng kontrata para construed against sa kanila pag
may doubt]

4. I am showing to you a provision in the outright agreement, (p. 3, par. 5. ANSWER), would you be so
kind as to read it?

5. The said clause did not categorically state that the terms of payment are within 45 days from the
date of the contract, correct?

6. So this is doubtful, is it not? (CONSTRUED AGAINST THE MAKER YUNG DOUBT NG CONTRACT)

7. So we are not in default, correct? DEFAULT PA RIN TAYO LINDS, COS EVEN IF IN FAVOR SA ATIN, 45
DAYS ENDS SA DECEMBER 4, TAPOS UNG DEMAND WAS DEC 18 but may defense na tayo dito. Baka
dangerous question lang

8. To avoid litigation, (p.3 par. 10 COMPLAINT; admission), SWIM proposed that 40% of the goods be
returned, correct?

9. Proceed to pullout…

Re: Pull-out

1. In your answer to the interrogatories, you sent a certain Macalinao to Cebu, correct?

2. What, if any, was the purpose of Mr. Macalinao’s travel to Cebu? [CUT SHORT NATIN PAG NAG
EXPLAIN SILA NA GANITO GANYAN]

3. Pictures of the store were attached as annex in the complaint, correct?

4. You said that there are about 24 shoes in the store? (RFA, admission) [WE SHOW THEIR ANS TO
RFA since wala sila jurat]

5. Considering that this is a non-issue, since the same is already admitted, would you agree with me
that the 24 shoes in the store is not enough to infer that the Shopsisters are not ready to allow the
agreed pullout?

6. Your complaint stated that our client is not ready to allow the pullout of the goods since a
significant amount of the goods are in the store, yes?

7. In compliance with the agreed obligation that SWIM will pullout (MISLEADING) the goods, you
went to our warehouse to pullout the goods, correct?

8. You stated in the complaint that you brought a multicab van, and you admitted that this is not
enough to carry all the goods, yes?
9. Then you would agree with me that there is no justified ground in suing Shopsisters, since SWIM is
the one who failed to pullout any goods, sans any fault on our part, correct?

10. You also said, in your answer in the interrogatories, that the rest of the goods were not pulled out
since they were missing in the warehouse, correct?

11. This is inconsistent with the allegations in your complaint, that the rest of the goods were not
pulled out since they were still displayed in the store, and that the “other half” of the goods are being
sold in the store, correct?

(WE SHOW THE COMPLAINT AND INTERROGATORIES; manifest it.)

[You, as the president of SWIM, had knowledge of the complaint filed against our client correct?]

[As the President of SWIM, you took effort and exercised proper diligence in reading the complaint, of
course?]

[And you, having the apparent authority to sue in behalf of SWIM, made sure that the allegations in the
complaint are true and correct, since the same is under oath, correct?]

[If so, shed light on the inconsistency on your complaint vis-a-vis your answer in the interrogatories.]

[Explain the inconsistency of the reason for the non-pullout.] NEED TO PART OF THE PREDICATE

12. The complaint is verified, yes?

13. Then you as the one with the apparent authority to bring suit can be held liable to perjury for
saying untruthful statements, correct? (OBJECTIONABLE -> being argumentative. Ok lang. adds to the
drama)