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REPUBLIC OF THE PHILIPPINES

Municipal Trial Court in Cities


Branch 1, Cebu City
JUAN ILOK,
Plaintiff,
-versus-

CIVIL CASE NO. CEB-12345

BRAD ARMPIT,
Defendant.
x--------------------------------------------x

FOR: SUM OF MONEY

PRE-TRIAL BRIEF
COMES NOW, plaintiff through the undersigned counsel and unto this
Honorable Court most respectfully submit this pre-trial brief to, wit:
I.
BRIEF STATEMENT OF FACTS
1.On March 1, 2007, Defendant is indebted to the plaintiff in the amount of ONE
HUNDRED FIFTY THOUSAND PESOS (P 150,000.00) without any written contract
and was witnessed by Pedro Siponon and Jose Kogmohon;
2. Subsequently, On July 20, 2007, defendant went to the house of the plaintiff to
cause partial payment in the amount of FIFTY THOUSAND PESOS (Php 50,000.00);
3. Consequently, the aforesaid payment was received by the plaintiffs minor son
aged 17 years old;
4. On July 31, 2007, defendant made its final payment in the amount of ONE
HUNDRED THOUSAND PESOS (P100,000.00) but the previous payment was not
received by the plaintiff in lieu that his son was not turn over the said money;
5. However, the plaintiff told the defendant that it was not his responsibility to
rectify the payment by mistake made by the defendant since the latter is still liable;
II.
NUMBER OF WITNESS TO BE PRESENTED

Plaintiff will present three (3) witnesses and barring long cross-examination,
in their testimonies could each be terminated in thirty (30) minutes.

III.
Abstract Testimonies of Witnesses for the Plaintiff
1.
2.

To substantiate plaintiffs claim as alleged in the complaint


To identify relevant documents to support Plaintiffs claim

IV.
Documents intended to be presented
Plaintiff reserves his right to present and mark his documentary exhibits in
the course of the proceedings of this case.
V.
Admissions
Plaintiff limits his admission to those alleged in the Complaint
VI.
Applicable Laws and Jurisprudence
Plaintiff reserves his right to submit the appropriate memorandum or position
paper citing the laws and jurisprudence applicable to this case.
VII.
Availment of Alternative Modes of Dispute Resolution
Plantiff is hereby willing to avail the possibility of settlement of claims by any
methods of Alternative Modes of Dispute Resolution.
VIII.
Issue
1.

Whether or not Plaintiff have causes of action against the defendant;

2.
Whether or not Plaintiff is entitled to any and all damages contemplated in
his Complaint.

RESPECTFULLY SUBMITTED UPON RECEIPT


October 3, 2016 Cebu City, Philippines
ATTY. PARK K. TILAOPAO
Counsel for the Plaintiff
Unit 1234 Apple One Building
Cebu City, Philippines
Roll No. 123453, IBP Member Lifetime 3/12/12
PTR No. 23124, Cebu City 12/31/15
MCLE Compliance No. VI-23455, Series of 2015

Copy Furnished:
Atty. DESIREE E. KURIMAO
Counsel for the Defendant
KURIMAO, KURIMAO and ABLAO LAW OFFICE
Suite 235 The Tower
Malate, Manila

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