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Pre Trial Brief Plaintiff
Pre Trial Brief Plaintiff
PRE-TRIAL BRIEF
(For the Plaintiff)
PLAINTIFF, through counsel, unto this Honorable court most respectfully submits
the following Pre-trial Brief:
I
BRIEF STATEMENT OF THE CASE
II
WILLINGNESS TO ENTER INTO AMICABLE SETTLEMENT OR
ALTERNATIVE MODES OF DISPUTE RESOLUTION
1
III
SUMMARY OF ADMITTED FACTS
Plaintiff’s admissions are limited to those matters that are alleged in her complaint.
IV
PROPOSED STIPULATIONS
V
ISSUE TO BE RESOLVED
1. Whether or not defendant voluntarily executed the promissory note attached in the
complaint on account of defendant’s indebtedness?
2. Whether or not Defendant is liable under the terms of the said promissory note?
VI
DOCUMENTARY EXHIBITS
1. Promissory note executed by Defendant on 12 December 2011;
2. Notice of Non-payment with a demand to pay dated 11 June 2014 which
Defendant received on 12 June 2014;
3. Respective Judicial Affidavits of witnesses.
VII
DISCOVERY PROCEDURES
Plaintiff is willing to avail of discovery procedures necessary for expedient resolution
of the issues involved.
VIII
NAMES OF WITNESSES
AND THE SUBSTANCE OF THEIR TESTIMONIES
1. Plaintiff who shall testify on the material allegations of her complaint;
2. Mr. Krisanto Alcaraz, plaintiff’s collector, who shall testify as to the non-payment
of defendant despite several demands from plaintiff;
2
3. Ms. Elsa Rodriguez who shall testify as to the details of the loan agreement such
as but not limited to the amount thereof, the amount of cash actually received by
defendant;
Plaintiff reserves the right to present the Judicial Affidavits of witnesses Lamberto
Lizada and Gerard Castillo to prove the allegations in her complaint.
IX
APPLICABLE LAWS AND JURISPRUDENCE
Respectfully submitted.