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Republic of the Philippines

SEVENTH JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 2 Iloilo City
Juan Ilok,
Plaintiff,
- versus -

Civil Case No. 4292324
For: Collection of sum of money

Brad Armpit,
Defendant.
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PRE-TRIAL BRIEF
DEFENDANT, by counsel, respectfully submits his Pre-Trial Brief, as follows:
1. POSSIBILITY TO ENTER INTO AN AMICABLE SETTLEMENT
a. Subject to a concrete proposal that is fair and reasonable and a reciprocal
manifestation of openness from defendant, plaintiff is open to settling this dispute
amicably,
b. 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 payment.
2. STATEMENT OF CLAIMS AND DEFENSES
a. Defendant failed to pay the remaining balance for his indebtedness
amounting to FIFTY THOUSAND PESOS (Php 50,000.00) for the money borrowed by
the defendant.
b. Defendant claims that the amount of FIFTY THOUSAND PESOS (Php
50,000.00) had been paid.
3. MATTERS ADMITTED
a. Defendant admits only those facts stated in their Answer.
4. ISSUES TO BE TRIED
a. Plaintiff submits that the following issue is subject to proof:
a1. The defendant failed to pay the remaining balance of FIFTY
THOUSAND PESOS,
b. Defendant submits that the following issues are subject to proof:

7. friend of the plaintiff and defendant. January 30. Mr. Plaintiff intends to present the following witnesses: a1. BINAYAS IBP No. ATTY. however. 6. b. to a concrete and reasonable request for discovery from defendant. 3570896 Roll No. 2008. EVIDENCE a. PHILLIP OWEN T. plaintiff does not intend to avail of discovery at this time. Ms. plaintiff reserves the right to resort to discovery before trial. 540-795-284. 61240 PTR No. Pedro Siponon. Plaintiff has received the total amount of ONE HUNDRED THOUSAND PESOS. a2. 2008. .b1. Subject. RESPECTFULLY SUBMITTED. 5. 2 March 2015. 67325 MCLE V-1110328 TIN No. Jose Kogmohon. to establish that the plaintiff and defendant actually met at the place of the plaintiff. Considering the relatively simple issues presented. AVAILABLE TRIAL DATES January 23. as witness to the transaction. RESORT TO DISCOVERY a. that the money owed was given to the defendant in the amount of FIFTY THOUSAND PESOS. Iloilo City.