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Mohar Ishmula,
Petitioner,
Anne Curtis-Smith,
Respondent.
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PRE-TRIAL BRIEF
Petitioner Mohar Ishmula through the undersigned counsel and unto his Honorable
Court most respectfully submits his pretrial brief:
This is an action for Declaration of Nullity of Marriage under Articles 36 & 68 of the
New Family Code.
Petitioner alleges in his Petition, viz: a) that petitioner and respondent are
husband and wife; b) that respondent is clinically found to be psychologically
incapacitated to comply with the essential requisites of marriage identified as
Narcissistic Personality Disorder with Anti-Social Traits w c) that the root cause of
such illness is traced from her respective childhood; d) such illness is diagnosed to be
grave and incurable; e) that such illness existed prior to the marriage and became
apparent at the time of the marriage.
Petitioner will be testifying on the allegations in the Petition and will present
documentary evidence.
ADMISSIONS
ISSUES
Whether or not Respondent is psychologically incapacitated to comply with the
essential requisites of marriage which is a valid ground under Art. 36 of the New
Family Code to declare the marriage a nullity.
Respectfully Submitted:
Atty
11th Avenue cor 39th Street
Bonifacio Triangle, Bonifacio Global.,
Taguig City
IBP No. 456789 dtd. 02-14-16 Quezon City
PTR No. 1434456 /01/14/97/ Pasig
Roll No. 334769752
MCLE Compliance II 0009868
Dtd. March 27, 2015
Copy Furnished:
EXPLANATION