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Presentation of Direct Testimony

I. Entry of Appearance

Lawyer: Good Morning/Afternoon Your Honor, I am Atty._____, appearing for the


Plaintiff/Respondent in this case, ______, represented by its_________. We are ready Your Honor.

Judge: What’s your pleasure?

II. Pending Incident

Lawyer: I would like to proceed with the presentation of evidence ex-parte your honor, on account
of the order granting our motion to declare the defendant in default issued on _____. With your
permission.

Judge: Proceed.

III. Presentation/Offer of Testimony

Lawyer: For my first witness, I would like to call on _____. I would like to offer her testimony to
identify and affirm the due execution and contents of:

1. Her Judicial Affidavit dated _______.


2. Annexes

IV. Preliminaries

Clerk: ( Oath)

Judge: Your witness.

Lawyer: Kindly state your name and personal circumstances for the record.

V. Direct

Lawyer: Do you remember executing a judicial affidavit in relation to this case?

Witness: Yes.

Lawyer: I’m handing you a judicial affidavit, please go over it and tell us the relation of the judicial
affidavit that you just mentioned to this judicial affidavit.

Witness: It’s the same.

Lawyer: This affidavit has been signed on top of the name ____. Kindly examine it and identify
whose signature it is.

Witness: It’s my signature.


Lawyer: Do you affirm the due execution and contents of this affidavit and that you answered the
questions truthfully?

Witness: Yes.

Lawyer: You made reference to Annex __ on page ___. Kindly go over this document and identify if
this is a faithful reproduction of the original.

Witness: It’s the same.

Lawyer: I would like to ask, Your Honor for the marking of this evidence as Exhibit A

Repeat…

Lawyer: No further questions. With your permission, I would like to proceed with my next witness.

VI. Closing

Lawyer: With your indulgence, Your Honor, I would like to ask for 10days from today to file a written
formal offer of documentary evidence,. After which, I would like to move for the submission of this
case for decision.

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