Professional Documents
Culture Documents
JABBA D. HUTT,
Plaintiff
PRE-TRIAL BRIEF
(FOR THE PLAINTIFF)
a. Promissory note
2 De Jesus v. Court of Appeals, G.R. No. 127857, June 20, 2006, 491 SCRA 325, 334
3 Rules of Court, Rule 130 Sec. 3 (d)
4 Rules of Court, Rule. 131 Sec. 3 (d); (q)
5 Rules of Court, Sec. 4
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1. That the contract is an investment of the plaintiff to the
Trade Federation Inc.
II. WITNESSES
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Plaintiff reserves the right to present such other witnesses as
the need may arise in this case.
Exhibits/Documents Purpose
Annex “C”: Post Dated Checks These prove that checks were
issued.
Annex “E”: Copy of the BoardThis proves that the act of Hans
Resolution No. 14 Solo is not Ultra Vires as it was
authorized by a Board Resolution.
Annex “G”: Proof of Receipt ofThis proves that the demand to pay
Demand Letter was actually received by defendant
Solo. Thus, it serves as a notice on
the part of defendant Solo that he
has an outstanding debt.
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Annex “H”: Copy of the SecondThis proves the second demand to
Demand Letter Sent pay defendant Solo’s debt. This
also notified defendant Solo that
the checks bounced due to ‘Closed
Account’. This contains the proof
that Solo received this letter but
still, to no avail.
IV. ADMISSIONS
VI. ISSUES
Kevin Harris Co
ROLL OF ATTORNEYS NO. 32173
IBP LIFETIME MEMBER NO. 1239-RSM
PTR NO. 2184563-06 January 2016-QC
MCLE COMPLIANCE NO. V-0009928-04/10/15
Genie C. Morales
ROLL OF ATTORNEYS NO. 37125
IBP LIFETIME MEMBER NO. 1248-RSM
PTR NO. 2184543-05 January 2016-QC
MCLE COMPLIANCE NO. V-0007929-04/10/15
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COPY FURNISHED:
EXPLANATION
Edward L. Concepcion
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