COMES NOW the defendant, by the undersigned counsel, and unto this Honorable Court, respectfully alleges:

      1. That the plaintiff's complaint in its paragraph____ alleges: "____________";

      2. That said allegation is insufficient and defective in that it fails to specify (here state the particulars desired);

      3. That a more definite statement on the matter as above indicated is necessary in order to enable the defendant to properly prepare his responsive pleading.

      WHEREFORE, it is respectfully prayed that an Order be issued by this Honorable court requiring the plaintiff to make more definite and certain his complaint in the particulars above indicated.

      Valenzuela City, __________________, 2004.