Republic of the Philippines

Regional Trial Court

First Judicial Region
Branch 3
Baguio City

PETE LIVINGSTONE, CIVIL CASE NO. 03

Plaintiff,

- versus - For:

PITAK REALTY INC., herein SPECIFIC PERFORMANCE

Represented by Chairman, and PAYMENT OF SUM OF
GLORIA BATONGBUHAY-GRACIA, MONEY
Defendant.
X-------------------------X

MOTION TO AMEND PRE-TRIAL BRIEF

TO INCLUDE A WITNESS

With all due respect to the Honorable Court, plaintiff through

undersigned counsel manifests that:

1. Plaintiff filed a Pre-trial Brief on 20 April 2018 with this Honorable

Court;

2. That the witness indicated in the Pre-trial Brief was the plaintiff alone;

3. However, the counsel inadvertently did not include one vital witness
which is Ga Tang, of legal age, Filipino, and a resident of #37 Lower Phil-
Am, Baguio City;

4. In view of the said inadvertence, undersigned counsel would like to

amend the Pre-trial Brief to include Ga Tang as an additional witness;

WHEREFORE, based on the premises presented, it is most

respectfully prayed for this Honorable Court to admit the attached amended
Pre-trial Brief.

Plaintiff also prays for other reliefs which may be just and equitable
under the premises.

Page 1 of 2
 Done this 26th day of April 2018.

CHARLIE PINGAWAN
Counsel for Plaintiff
Roll No. 1234
IBP Membership No. 123
PTR No. 2013-119
MCLE No. 2013-123
Baguio City

COPY FURNISHED:

MA. CRISTINA BRIONES

Counsel for the Defendant
Nagiisip Law Office
1 Session Road Building, Session Road
PTR NO. 12345678
Roll No. 23156
IBP No. 00505 (Lifetime)

Page 2 of 2