REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

SIXTH JUDICIAL REGION
BRANCH ___ BACOLOD CITY
NEGROS OCCIDENTAL

PEOPLE OF THE PHILIPPINES

Complainant,

CRIM. CASES NOS. 12345

Versus

DR. KWAK
Accused
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PRE-TRIAL BRIEF
FOR THE ACCUSED

COMES NOW, Accused, thru the undersigned counsel, to this

Honorable Court, most respectfully submits his pre-trial brief, and states
that:

I.
SUMMARY OF ADMITTED FACTS BY THE ACCUSED

1. That this Honorable Court has jurisdiction over the subject matter of
this case;

2. The personal circumstances of the Petitioner and the Respondent;

3. The fact of the marriage of the Petitioner and Respondent;

II.
FACTS PROPOSED FOR ADMISSION BY
OR STIPULATION WITH THE COMPLAINANT

Accused respectfully proposes the following for the admission by or

stipulation with the Private Complainant/Prosecution:

1. Will the prosecution admit the due execution and the veracity of
the content of the Statement of Income and Expenses for the year
ended Dec. 31, 2014 duly signed by the private complainant?
 2. Will the prosecution admit that the accused is giving the private
complainant 7,000 a month to buy for her personal and private
needs?
3. Will the prosecution admit that during their marriage, the accused
is providing 30,000 a month for the groceries and other
household expenses?

III.
DOCUMENTARY EVIDENCE

Petitioner intends to present the following documentary evidence:

1. Exhibit “1” Statement of Income and Expenses

2. Exhibit “2” Bank Deposit Slip
3. Exhibit “3” TCT No. 12345
4. Exhibit “4” Police Blotter
5. Exhibit “5” Facebook Photos
6. Exhibit “6” Cebu Vacation Photos
7. Exhibit “7” Screenshots of the text messages

Petitioner reserves her right to adopt, mark and present additional

documentary exhibits in the course of the trial, if necessary;

IV.
TESTIMONIAL EVIDENCE

Petitioner intends to present the following witnesses:

1. Reynold Isac
2. Iban Hoe
3. Rest Enrec
4. Bank Representative
5. Petitioner reserves his right to present additional witnesses in the
course of the trial, if necessary;

VI.
ISSUES
 1. Whether or Not the Accused is guilty of the crime charged in
the information?

AVAILABLE DATES FOR TRIAL

The Accused respectfully requests that the trial dates be agreed

upon in open court at such dates and time convenient to the parties and
the calendar of this Honorable Court.