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    Pre Trial Brief For Sum of Money

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    Magnolia Masangcay-Dalire
    This document is a Plaintiff's Pre-Trial Brief for a case in the Regional Trial Court of Makati City regarding a sum of money and damages. It provides details of the Plaintiff's case including a willingness for amicable settlement, a statement that the Plaintiff loaned money to the Defendant per a Promissory Note that was not fully repaid, a list of planned documentary and testimonial evidence, the issues to be resolved in determining damages owed, and relevant laws. It reserves the right to amend pleadings and discuss trial dates at the pre-trial hearing.

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    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd

    Pre Trial Brief For Sum of Money

    Uploaded by

    Magnolia Masangcay-Dalire
    790 views2 pages
    This document is a Plaintiff's Pre-Trial Brief for a case in the Regional Trial Court of Makati City regarding a sum of money and damages. It provides details of the Plaintiff's case including a willingness for amicable settlement, a statement that the Plaintiff loaned money to the Defendant per a Promissory Note that was not fully repaid, a list of planned documentary and testimonial evidence, the issues to be resolved in determining damages owed, and relevant laws. It reserves the right to amend pleadings and discuss trial dates at the pre-trial hearing.

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    Pre Trial Brief for sum of money

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    Pre Trial Brief for sum of money

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    This document is a Plaintiff's Pre-Trial Brief for a case in the Regional Trial Court of Makati City regarding a sum of money and damages. It provides details of the Plaintiff's case including a willingness for amicable settlement, a statement that the Plaintiff loaned money to the Defendant per a Promissory Note that was not fully repaid, a list of planned documentary and testimonial evidence, the issues to be resolved in determining damages owed, and relevant laws. It reserves the right to amend pleadings and discuss trial dates at the pre-trial hearing.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    790 views2 pages

    Pre Trial Brief For Sum of Money

    Uploaded by

    Magnolia Masangcay-Dalire
    This document is a Plaintiff's Pre-Trial Brief for a case in the Regional Trial Court of Makati City regarding a sum of money and damages. It provides details of the Plaintiff's case including a willingness for amicable settlement, a statement that the Plaintiff loaned money to the Defendant per a Promissory Note that was not fully repaid, a list of planned documentary and testimonial evidence, the issues to be resolved in determining damages owed, and relevant laws. It reserves the right to amend pleadings and discuss trial dates at the pre-trial hearing.

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    © All Rights Reserved
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    REPUBLIC OF THE PHILIPPINES

    REGIONAL TRIAL COURT


    NATIONAL CAPITAL JUDICIAL REGION
    BRANCH 132
    CITY OF MAKATI

    ___________________,
    _________________
    Plaintiff,

    -versus-

    _________________ and
    JOHN DOE(S),
    Def
    endants.

    PLAINTIFFS PRE-TRIAL BRIEF

    PLAINTIFF, by the undersigned counsel, most respectfully


    submits this Pre-Trial Brief.

    1.0 On the Possibility of Amicable Settlement

    Plaintiff is open for discussions on the possibility of having this


    case settled amicably if only to avoid prolonged litigation of the case.

    2.0 Statement of Plaintiffs Case

    This is a case for Sum of Money & Damages. As stated in the


    Complaint, ___________________________________________.

    3.0 Admissions/Stipulations

    Apart from the Plaintiffs allegations of facts in the Complaint,


    no further offer of stipulation of facts is deemed necessary.

    4.0 Plaintiffs List of Evidence

    4.1 Documentary

    a. Promissory Note with Chattel Mortgage


    b. Certificate of Registration
    d. Certificate of Sale
    e. Demand Letter
    f. Statement of Account
    g. Board Resolution

    4.2 Testimonial

    Plaintiff will present at least two (2) witnesses who will testify
    on and identify the documentary evidence, execution of the
    Promissory Note with Chattel Mortgage, Defendants failure to
    fail their amortizations, subsequent voluntary surrender of the
    subject units and sale, insufficiency of the proceeds of the sale
    to cover the outstanding obligation and defendants refusal to
    pay their outstanding obligations.

    5.0 Proposed Issue to be Resolved

    1. Whether or not the Plaintiff is entitled to the sum of


    _________________, as and by way of actual damages, with
    interest and penalty charges, as stipulated, from
    ________________ until fully paid, attorneys fees and
    liquidated damages.

    6.0 Laws and Jurisprudence Involved

    a. Pertinent provisions of the Civil Code of the Philippines on


    Obligations and Contact, Credit Transactions.

    b. Applicable decisions promulgated by the Supreme Court of the


    Philippines relative to the facts and issue of the instant case.

    7.0 Plaintiffs Reservation

    Plaintiff reserves the right to present additional documentary


    and testimonial evidence and witnesses, and the right to amend its
    pleadings in the course of the trial.

    8.0 Available Trial Dates

    The undersigned counsel proposes to discuss the trial dates


    with the opposing counsel during the pre-trial hearing so as to avoid
    conflict of schedules.

    Respectfully submitted.

    Makati City, ______________________.

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