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JOLLEANNE PERINO
Defendant,
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PRE-TRIAL BRIEF
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II. BRIEF STATEMENT OF CLAIMS AND DEFENSES
2.2 On or about August 15, 2019, Plaintiffs discovered that the tax
declaration of the property was transferred to the Defendant by virtue
of a forged deed of sale;
2.3 On the assumption that the sale was valid, the Children-Plaintiffs
are still entitled to their shares out of the one-half of the land
appertaining to their deceased father, Juan Suarez;
2.4 On the other hand, the Defendant claims that Plaintiff Rosana Vda.
de Suarez represented that the property was paraphernal. The
Defendant acquired the property not only by a valid public document
of sale but also by prescription.
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3.3 That the aforesaid property has been subject of the cadastral
survey and denominated as Cadastral Lot No. 16304-CAD-10
Ext. It is bounded on the North by Lot No. 12341; On the East
by Lot No. 12343; on the South by Lot No. 12344 and on the
West by Lot No. 12346;
4.1 Whether or not the thumb mark of the Deed of Sale (Annex
“D” to the Complaint) was a forgery;
4.3 Assuming that the Deed of Sale was genuine, whether or not
the Plaintiffs, except their mother Rosana, have shares over
the one-half portion of the property;
V. EVIDENCE
5.3 Tax Declaration No. 67890, for the year 2015, in the name
of Rosana Suarez (Annex “A”);
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VI. RESORT TO DISCOVERY
Copy furnished:
By Personal Service