REPUBLIC OF THE PHILIPPINES

JUDICIAL REGION
TRIAL COURT
BRANCH -----CITY

NAME,
Plaintiff,

-vs- Civil Case No. ______

For: Sum of Money

NAME,
Defendant.

x---------------------------------------------x

PRE-TRIAL BRIEF OF THE DEFENDANT

DEFENDANT, by counsel, respectfully submits this Pre-Trial Brief

and states:

POSSIBILITY OF AMICABLE SETTLEMENT

Defendant is willing to submit to alternative modes of dispute

resolution and to enter into an amicable settlement of the case, under
reasonable terms and conditions acceptable to both parties.

STIPULATION OF FACTS

Defendant limits its admission to those mentioned in its Answer

and proposes for admission by the plaintiff the return of ---------
deductible from the account of the defendant.

ISSUE

1. Whether or not the plaintiff has a cause of action in the instant

case;

2. Whether or not the obligation being demanded by plaintiff exists

or has been extinguished.

WITNESSES
 _______ will testify on the material allegations in the defendants
answer and identify pertinent documents. Defendant reserves the right
to present any other witnesses whose testimony will become relevant to
belie plaintiffs averments.

DOCUMENTS TO BE PRESENTED

Defendant will present the following documents as evidence:

a. The Secretarys Certificate granting the authority to _____ for

purposes of this case.
b. The Pictures depicting the ______
c. The Copy of the Inventory of the --------.
d. Copies of Complaint Affidavit for theft and estafa against the
defendants employees.

Defendant reserves the right to present other documents which

shall become relevant in the course of trial.

APPLICABLE LAWS

The New Civil Code of the Philippines provisions on Obligation

and Contracts, Sales, the Rules of Court as well as relevant
jurisprudence.

TRIAL DATES

The dates that may be agreed upon by the parties and convenient
to the calendar of this Honorable Court.

WHEREFORE, defendant respectfully prays that submission of

this Pre-Trial Brief be noted.

Respectfully submitted.

Lipa City, Date

OFFICE
Law and Notarial Offices
Counsel for the Defendant
 By:

LAWYER
Roll of Attorneys No. ----
PTR No. ---
IBP No. ---
MCLE Compliance No. V-0015499; 3/11/2016

Copy Furnished:

NAme
Address

EXPLANATION

This Pre-Trial Brief is being served to the other party and filed
with the Honorable Court by registered mail, personal mode of service
being impracticable due to distance involved and lack of personnel to
effect the same.

Lawyer