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EDSEL CO LIM,
Petitioner,
Civil Case No. 708999
-versus-
For: PETITION FOR
LEGAL SEPARATION
TIMOTHY ANG LIM,
Respondent.
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law, respectfully submits to this Honorable Court this Pre-Trial Brief, to wit:
I.
undergo alternative modes of dispute resolution with respect to the primary prayer
settlement in relation to the partition and accounting of the conjugal properties and
II.
10.That the couple did not enter into any marriage settlement is deemed
admitted.
11.
III.
Honorable Court:
essential marital obligations stated under Article 68 of the Family Code, was
existing at the time of the marriage, though only manifesting itself during
the marriage.
IV.
DOCUMENTS TO BE PRESENTED
WITNESSES TO BE PRESENTED
2. Dr. ___ will testify as to the truthfulness of the Medical Exam Result
showing proof of Chlamidia made on ___. He will also testify as to how
chlamydia is contracted and how it is transmitted.
VI.
RESORT TO DISCOVERY
VII.
The Respondent respectfully requests that the trial dates be agreed upon in
open court at such dates and the time convenient to the parties and the calendar of
By:
(SGD.) JULIUS C. DIMACULANGAN
Counsel for the Respondent
Roll of Attorney No. 76682
IBP No. 12345/1-5-12/Manila
PTR No. 87654/12-22-12/Manila
AFFIRMATIVE DEFENSES
3. Respondent never abandoned petitioner and their child and would continually
support them from the proceeds of the shares that Respondent holds at the Manila
Polo Club as attached hereto and marked as [9]Annex I;
10. Based on all the foregoing, the Petitioner clearly has no cause of action
against respondent.