NOVEMBER 18, 2014

16TH Floor (dulo), Makati City Hall

For: Preliminary Investigation
Assistant City Prosecutor Jesus C. Labriaga
Clerk : Ms. Vivian
1. Give the folder to Miss Vivian. Tell her that I am a representative from the office of Atty. Mike
Danganan and that I am submitting a copy of the counter-affidavit.
2. Wait to be called.
3. Do not sign as a lawyer. Sign as representative of LOCUS Law.
4. Go to Fiscal. Introduce myself as representative from the office of Atty. Mike Danganan.
5. Two possible scenarios:
a. If the counsel of the other party is NOT PRESENT:
i. Submit the counter-affidavit. Manifest that the respondent is in Perth, Western
Australia and that he executed the attached instrument in the presence of the
Consul General.
ii. Explain to the fiscal that the original was printed on an A4 paper so the bottom
part was removed.
iii. However, show a copy of the counter-affidavit which was printed on a long
bond paper for the fiscals perusal.
iv. If the fiscal is not amenable, ask for time for us to rectify the fault and ask for a
next setting.
v. If it is okay with the fiscal, then present the same. The fiscal will then ask Any
pleasure? Reply by submitting the case for resolution.
vi. Sign whatever is necessary to be signed.
b. If the counsel of the other party is PRESENT:
i. Submit the counter-affidavit. Furnish the other party with a copy.
ii. The other party will ask for time to file a reply. Allow only a submission of until
two weeks.
iii. The other party will submit the case for resolution.
iv. Request the fiscal for leave to file a REJOINDER. Ask for the next setting.
v. Sign whatever must be signed.
6. Upon returning to the office, prepare the following:
a. Status Report
b. DTS
c. Reimbursement Form