Republic of the Philippines

REGIONAL TRIAL COURT

5th Judicial Region
Branch 6
Legazpi City

LADY SANSA STARK,

Plaintiff,

- versus - Civil Case No. 111111

For: Collection of sum of money

LORD PETYR BAELISH,

Defendant.

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PRE-TRIAL BRIEF

DEFENDANT, by counsel, respectfully submits his Pre-Trial Brief, as follows:

I. WILLINGNESS TO ENTER INTO AN AMICABLE SETTLEMENT AND POSSIBLE

TERMS OF ANY SUCH SETTLEMENT

1.1. Plaintiff is open to settling this dispute amicably, subject to a concrete

proposal that is fair and reasonable and a reciprocal manifestation of openness

from defendant,

1.2. Pursuant to Rule 18 of the 1997 Rules of Civil Procedure, plaintiff

respectfully submits that the desired terms of any amicable settlement would

involve, first, an admission of amount due and owing to plaintiff and, second, a

schedule of payments.

II. BRIEF STATEMENT OF CLAIMS AND DEFENSES

2.1 Plaintiff claims that defendant failed to pay the purchase price of FIVE

HUNDRED THOUSAND PESOS (Php 500,000.00) for the Rolex watch delivered

to the defendant.
 2.2 Defendant raise as defenses that no sale ever transpired and that the checks

issued to Ms. Stark were stolen and the defendant’s signature forged.

III. FACTS AND OTHER MATTERS ADMITTED BY THE PARTIES

3.1. Defendant admits only those facts stated in their Answer, i.e., their personal

circumstances and the existence of the bank account and corresponding checks.

IV. ISSUES TO BE TRIED

4.1. Plaintiff submits that the following issue is subject to proof:

4.1.1. The loss of the defendant’s checks as the cause for the account’s

closure and forgery of his signature

4.2. Defendant submits that the following issues are subject to proof:

4.2.1. There was a contract of sale with the plaintiff;

V. EVIDENCE

5.1. Plaintiff intends to present the following witnesses:

5.1.1 Mr. Brandon Stark, to establish that the plaintiff and defendant

actually met at the Tree of the Old Gods Hotel, that the Catspaw Dagger

Necklace was the subject matter of a contract of sale between the plaintiff

and defendant, and that the defendant paid in cash FOUR HUNDRED

THOUSAND PESOS (P400,000) and issued the checks covering the

balance;

5.1.2 Ms. Brienne Tarth, manager of the hotel restaurant, as witness to the

meeting and the transaction;

5.2. Plaintiff reserves the right to present any and all documentary evidence,

which shall become relevant to rebut defendants’ claims in the course of trial as

well as any other witnesses whose testimony will become relevant to belie

defendants’ witnesses, if necessary.

VI. RESORT TO DISCOVERY

6.1. Considering the relatively simple issues presented, plaintiff does not intend

to avail of discovery at this time;

6.2. Subject, however, to a concrete and reasonable request for discovery from

defendant, plaintiff reserves the right to resort to discovery before trial.

VII. AVAILABLE TRIAL DATES

May 17, 2018, May 23, 2018, May 30, 2018 and June 4, 2018

RESPECTFULLY SUBMITTED.

Legazpi City. 11 May 2018.

Ramos, Ramos, Ramos, Ramos and Ramos

Counsel for the Plaintiff
372nd Floor Burj Al Khalifa Building
Legazpi City, Philippines

By:

ATTY. CHARLES DEAN A. RAMOS

IBP No. 091595 04/16/2018 Legazpi City
PTR No. 121915 09/15/2018 Legazpi City
Roll No. 121915
MCLE Compliance No. II 01-23456

Copy Furnished:
By Personal Service

ATTY. MENS REA

Aegis Juris Law Office
275th Floor Burj Al Khalifa Building
Legazpi City, Philippines