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1. State that there was filing of complaint and answer

2. Plaintiff moved for pre trial
3. In preliminary conference
a. For the defendants your honor respectfully appearing for the
defendant Roldan Figueras, Atty. Krystel Grace Calderon
b. Stipulation for the plaintiff, so plaintiff will state their facts and
defendant will either admit or deny
c. Traffic accident report- Not admitted
d. The existence, due execution and authenticity of the traffic
accident report marked as annex d of the
e. As to for the defendants, Your honor we can admit as to the
existence only of the document. Whether or not as to the due
execution subject for trial
f. As to receipts, admit the existence but not as to the due execution

Defendant
1. Will the plaintiff admit as to the existence… of the costs of the burial etc
2. Admit as to the existence as to the hospital costs..

3. Frame the issue

PAR 3
1. Fact of death- admitted as to the fact of the incident
2. Denied for lack of personal knowledge
3. Defendant: Your honor that is highly prejudicial

DEFENDANT’S SIDE
DEFENDANT’S PROPOSALS:
1. Just read all the proposals in the pre-trial brief
DOCUMENTARY EXHIBITS
1. Exhibit one your honor s the expenses, can we also ask the plaintiff to
admit that these photocopies are faithful reproduction of …..
ISSUE
We propose your honor the following issues

PRE-TRIAL
SETTLEMENT
For the defendant your honor, we would like to manifest to settle this case
amicably but we cannot accept the amount being demanded but only up to
500,000.

STIPULATION OF FACTS
1. Your honor considering that we have a copy of the certificate of live birth,
therefore we admit the proposal.
2. CRIM CASE:
Document
Your honor for the defendants, we would like to mark as Exhbit 1 the various
receipts already pre marked as Annex 1. Can we also ask the plaintif to
compare the copy as faithful reporoduction
Your honor we would like to make reservations

Your honor upon perusal and upon examination we admit as to its faithful
reproduction.