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-versus-
A. AS TO THE POSSIBILITY OF
ENTERINGINTOAN
AMICABLE SETTLEMENT
OR ALTERNATIVE
MODESOF DISPUTE
RESOLUTION:
B. SUMMARY OF ADMITTED
FACTS AND PROPOSED
STIPULATION OF FACTS:
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The defendants will not be making any additional admissions other
than those already admitted in theirAnswer.
C. ISSUES:
a. Are the plaintiffs liable for unpaid rents for the entire period of the
Contract of Lease?
b. Are the plaintiffs liable for the cost of cleaning and repair of damages
on the leased property?
c. Are the plaintiffs entitled to a refund of their P55,000.00 deposit
despite their breach of the Contract of Lease?
d. Who between the parties are entitled to actual, moral, and exemplary
damages?
e. Who between the parties are entitled to attorney’s fees?
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c) Exhibit “3” and series - Photographs of the leased premises after the
plaintiffs abandoned it on January 2002 – to show the damages caused
and the untidy and disorderly condition of the place;
d) Exhibit “4” and series - Receipts of the expenses spent for materials
and labor for the cleaning and repair of the leased premises;
e) Exhibit “5” and series - RetainershipAgreement between the
defendants and their counsel, and receipts of litigation expenses – to
support the attorney’s fees and other litigation expenses claimed
against the plaintiff; and
f) The defendants reserve the right to present additional exhibits as may
be necessary during the trial.
E. MANIFESTATION TO AVAIL
OF DISCOVERY PROCEDURE:
The plaintiffs will present atleast three (3) witnesses and reserve the
right to present additional witnesses if the need arises during the trial of the
case, namely:
H. TRIAL DATES:
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The defendants will need at least four (4) trial dates to present their
evidence. Available trial dates of the parties and their counsels shall be
discussed and agreed upon during the pre-trial of this case.
RESPECTFULLY SUBMITTED.
COPY FURNISHED:
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