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(Pre-Trial Brief - for Plaintiff) (CAPTION) PRE-TRIAL BRIEF PLAINTIFF, by counsel and unto the Honorable Court, most

respectfully submits this Pre-Trial Brief: Willingness to Enter into Amicable Settlement Plaintiff is open and willing to enter into an amicable settlement or compromise under the following terms: 1. __________________________ 2. __________________________ 3. __________________________ Alternative Modes of Dispute Resolution Plaintiff is willing to submit itself to mediation and other alternative modes of dispute resolution. Brief Statement of Case This is a case for __________________________.

Admitted Facts Plaintiff admits the following facts: 1. __________________________ 2. __________________________ 3. __________________________

Plaintiff is open to stipulations over and above the foregoing admissions. Proposed Stipulation of Facts Plaintiff requests Defendant to admit the following facts: 1. __________________________ 2. __________________________ 3. __________________________ Issues Plaintiff respectfully submits that the issues in this case are: Whether or not __________________________ Whether or not __________________________ Whether or not __________________________ List of Exhibits to be presented Plaintiff will present the following exhibits: 1. ____________________ - to prove that _____State the Purpose_____ 2. ____________________ - to prove that _____State the Purpose_____ 3. ____________________ - to prove that _____State the Purpose_____ Witnesses to be presented Plaintiff will present the following witnesses: Plaintiff (himself/herself) - to testify on the materials allegations, causes of action, and claims as set forth in the Complaint; _____________ - to corroborate the testimony of the Plaintiff on its material points and to testify that __________________________;

_____________ - to corroborate the testimony of the Plaintiff on its material points and to testify that __________________________; Plaintiff will need at least ___________ (______) (hour/minutes) per witness, exclusive of cross-examination, rebuttal and sur-rebuttal evidence.

Reservation Plaintiff expressly reserves the right to present such additional witnesses and other exhibits and evidence as the exigencies of the trial may require. Specific Trial Dates It is respectfully requested that the trial dates be set during the pre-trial conference to dates most convenient to this Honorable Court and to all the parties. MOST RESPECTFULLY SUBMITTED. _____________, Philippines, __Date__.

(COUNSEL)

COPY FURNISHED:

OPPOSING COUNSEL

(EXPLANATION)

(Pre-Trial Brief - for Defendant) (CAPTION) PRE-TRIAL BRIEF DEFENDANT, by counsel and unto the Honorable Court, most respectfully submits this Pre-Trial Brief: Willingness to Enter into Amicable Settlement Defendant is open and willing to enter into an amicable settlement or compromise under the following terms: 1. __________________________ 2. __________________________ 3. __________________________ Alternative Modes of Dispute Resolution Defendant is willing to submit itself to mediation and other alternative modes of dispute resolution. Brief Statement of Defense Defendant, in its Answer with Counterclaims, dated _____________, prays for the dismissal of the complaint on the ground that _____________.

Admitted Facts Defendant admits the following facts: 1. __________________________

2. __________________________ 3. __________________________ Defendant is open to stipulations over and above the foregoing admissions. Proposed Stipulation of Facts Defendant requests Plaintiff to admit the following facts: 1. __________________________ 2. __________________________ 3. __________________________ Issues Defendant respectfully submits that the issues in this case are: Whether or not __________________________ Whether or not __________________________ Whether or not __________________________ List of Exhibits to be presented Defendant will present the following exhibits: 1. ____________________ - to prove that _____State the Purpose_____ 2. ____________________ - to prove that _____State the Purpose_____ 3. ____________________ - to prove that _____State the Purpose_____ Witnesses to be presented Defendant will present the following witnesses:

Defendant (himself/herself) - to testify on the materials allegations, affirmative allegations, and special and affirmative defenses and the denials in (his/her) Answer and Counterclaims and to testify on the damages caused to (him/her) by the filing of this action; _____________ - to corroborate the testimony of the Defendant on its material points and to testify that __________________________; _____________ - to corroborate the testimony of the Defendant on its material points and to testify that __________________________; Defendant will need at least ___________ (______) (hour/minutes) per witness, exclusive of cross-examination, rebuttal and sur-rebuttal evidence.

Reservation Defendant expressly reserves the right to present such additional witnesses and other exhibits and evidence as the exigencies of the trial may require. Specific Trial Dates It is respectfully requested that the trial dates be set during the pre-trial conference to dates most convenient to this Honorable Court and to all the parties. MOST RESPECTFULLY SUBMITTED. _____________, Philippines, __Date__.

(COUNSEL)

COPY FURNISHED:

OPPOSING COUNSEL

(EXPLANATION)