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Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES
Branch 25
Iloilo City

REYNOLD G. TANZA,
Plaintiff,
Civil Case No. 324
FOR: Unlawful Detainer

-versusARDIE JAY F. DAVIDE,
Defendant.
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PRE-TRIAL BRIEF

PLAINTIFF, 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. 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.
II. BRIEF STATEMENT OF CLAIMS AND DEFENSES
1. The defendant failed to pay the agreed rental from August 2014 up to
the present and is continuously occupying the same although he failed
to renew the contract of lease. Even after several and repeated
demands, the defendant continues to illegally occupy the subject
property;
2. The plaintiff now institute this action for unlawful detainer for the
continued possession by the defendant of the subject property is
prejudicial to the rights of the plaintiff.
III. FACTS AND OTHER MATTERS ADMITTED BY THE PARTIES
1. Plaintiff admits the personal circumstances of the parties as stated in
the compliant and answer.

Whether or not defendant should be ejected from the subject property. IV. Defendant reserves the right to present other witnesses not herein enumerated as deemed necessary. VII.2. EXHIBITS MARKED AS DOCUMENTS TO BE PRESENTED Exhibit A. ISSUES TO BE TRIED 1. 2. AVAILABLE TRIAL DATES The plaintiff would depend on the dates agreed upon during the pretrial. 2011. RESPECTFULLY SUBMITTED. WITNESSES TO BE PRESENTED 1.A machine copy of the Contract of Lease between plaintiff and defendant last April 30. . VI. Plaintiff further admits the facts stated in his complaint only. Exhibit B – A machine copy of the demand letters by the plaintiff to the defendant. V. The plaintiff himself – to testify regarding the unlawful continued possession by the defendant of the subject property. The plaintiff reserves his right to present other documents not herein listed as may be deemed necessary.

Iloilo City. 2015 . 01/06/14. Iloilo City Received on March 26. MA. VINCENT ENRIQUE A. 123456. Jaro. Alta Tierra Village. Iloilo City MCLE Comp. Iloilo City Roll of Attorneys No. ATTY. Iloilo City IBP NO. 01/02/14 COPY FURNISHED: BY PERSONAL SERVICE ATTY. DOLDUCO Counsel for the Defendant Dolduco Law Office. 01/04/14. Lapaz. VARONA Counsel for the Plaintiff Varona Law Office. No. IV-0009876. 54321 PTR NO. 654321. March 25. Mission Extension Street. 2015. CASSIE JEAN D.