Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

9th Judicial Region
Branch 6, Zamboanga City.

JONEL X. AFAM,
Plaintiff,
Civil Case No. 143
- versus -
For: COLLECTION OF
SUM OF MONEY
LEILA D. SARAP,
Defendant,
x-----------------x

PRE-TRIAL BRIEF
(For Plaintiff)

COMES NOW, the Plaintiff, through the undersigned counsel,

before this Honorable Court, most respectfully submits this Pre-Trial Brief
and allege the following:

I. WILLINGNESS TO ENTER INTO AMICABLE SETTLEMENT

The Plaintiff is willing to enter into an amicable settlement that is just and
fair under the circumstances;

II. SUMMARY OF PROPOSED STIPULATIONS

1. The identity of parties as Plaintiff and Defendant;
2. Defendant executed a Promissory Note on September 14, 2018 in
favor of the Plaintiff;
3. Despite being served demand letters, Defendant failed, neglected and
refused to pay the amount due to the Plaintiff. The parties even
undergo the process of barangay conciliation and there being no
amicable settlement arrived at.

III. ISSUE/S
Whether or not the Plaintiff is entitled to recover the sum of money.

IV. DOCUMENTARY EVIDENCE TO BE PRESENTED

1. Exhibit “A”- Promissory Note;

2. Exhibit “B-1 to B-3”- Demand Letters;

3. Exhibit “C”- Certificate to File Action;

4. Exhibit "D" - Judicial Affidavit of the Plaint;
5. Exhibit "E" - Judicial Affidavit of the Witness

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 V. TESTIMONIAL EVIDENCE

1. Plaintiff JONEL X. AFAM

Purpose: To prove that there was a promissory note made in his favor
and that despite serving demand letters the defendant failed, neglected
and refused to pay the amount due.

2. Witness RUD W. IGO

Purpose: To prove that the promissory note executed in the favor of the
Plaintiff.

VI. AVAILMENT OF MODES OF DISCOVERY

NONE

VII. TRIAL DATES

Subject to the Honorable Court’s calendar and availability of parties.

RESPECTFULLY SUBMITTED. This 10th day of April 2019, in the City of

Zamboanga, Philippines.

By:

ATTY. ALVN RYAN S. KIPLI

Counsel for Plaintiff
KIPLI Law Office
Room 304, Madrigal Bldg., ZC
IBP No. 610577; 12-27-2015
Roll No. 47753 - 05/05/2000
PTR No. 1198874/ Jan-7-2016
Zamboanga City
Initial MCLE Compliance as per Bar Matter 850 -5-8-13
MCLE V 0007309, May 5, 2014
Email: alvinryank@yaoo.com, 0935-446-4502

COPY FURNISHED:
Copy Furnished:
Liklok Office thru Atty. Lala B. Bee

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No. 1, 2nd Floor, LB Building,
Baliwasan, Zamboanga City

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