REPUBLIC OF THE PHILIPPINES

3rd Judicial Region

MUNICIPAL TRIAL COURT
Branch 2
Tarlac City
JUANA VALDEZ,
Plaintiff,

- versus - Civil Case No. 000000

For: Collection of sum of money

MIGUEL LAZARO,
Defendants.

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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 sum of money delivered to the

defendant.
 2.2 Defendant raise as defenses that no transaction transpired and that there is no money

given to Juana.

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.

IV. ISSUES TO BE TRIED

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

4.1.1. There was a contract with the plaintiff;

V. EVIDENCE

5.1. Plaintiff intends to present the following witnesses:

5.1.1 Ms. Cherry Alcatel, to establish that the plaintiff and defendant actually met at the

Magic Star Mall, where the transaction happened.

5.1.2 Cherry Boom Tarat, manager of the mall, 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

December 6, 2017, December 20, 2017, and January 5, 2017

RESPECTFULLY SUBMITTED.

Tarlac City. 1 December 2017.

______________
Counsel for the Plaintiff
Counsel for the Plaintiff
Maluid, Victoria, Tarlac
Contact No. 0927-593-0204

By:

______________
IBP # 605482 1/8/11 Tarlac City
PTR # 0417576 1/8/11 Tarlac City
ROA 30724
MCLE Compliance No. II 01-23455

Copy Furnished:
By Personal Service
_________
Counsel for the Plaintiff
Maluid, Victoria, Tarlac
Contact No. 0927-593-0204