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Republic of the Philippines

Municipal TRIAL COURT


5th Judicial Region
Branch___
NAGA CITY

RAHOOL ANGHELLYES
Plaintiff,

-vs- Civil Case No. __________


For: Collection of Sum of Money

EDDIE WARD
Defendant.
x--------------------------------------------x

PRE-TRIAL BRIEF

Complainant, by counsel, and unto this Honorable Court, respectfully


submits his Pre-trial brief in compliance with this Honorable Courts

POSSIBILTY OF AMICABLE SETTLEMENT AND SUBMISSION TO ALTERNATIVE MODES


OF DISPUTE RESOLUTION
1.1 RAHOOL ANGHELLYES respectfully manifests, without admitting
liability or waiving any of his rights or defenses, that he is open to any reasonable
proposal for amicable settlement from EDDIE WARD or referral of the case to
alternative modes of dispute resolution, including mediation and or judicial
dispute resolution.

STATEMENT OF PLAINTIFF'S CLAIM

2. 1. Defendant came in to Plaintiffs EBAKS SIPSIP INTL SERVICES


engage in waste cleaning operations that he will be allowed to pay fee of
P120, 000 .00
2.2. The reality in this case is that ,defendant failed to pay the services rendered by the
plaintiff as agreed in contract of services and now denying the promissory note that he had
sign, and claiming that the signature in the said Promissory note and contract of agreement was
forge. Also the plaintiff did reasonable effort to arrive in settling the dispute but the defendant
wont cooperate and repeatedly reject and deny the notice of demand of the Plaintiff

WITNESS AND ABSTRACT OF TESTIMONIES


3.1. Plaintiff
Present evidence to support his claim about the facts of the
case.
3.2. Plaintiffs Secretary
Present evidence to prove that Defendant was present in their
office and signed the said Contract of agreement and promissory note

STIPULATION OF FACTS

The identity of the parties and that plaintiff will make their proposal and
counter-proposals in open court and admit those already pleaded in the pleadings and
make reservation of any issues that may come out in the course of the Pre-trial
Proceedings and trial proper.

DOCUMENTS

Those attached to the pleadings and other reserves which will be presented in
the course of the proceedings.

RESPECTFULLY SUBMITTED.

Naga City, ______________________.

By:

Heinrich Himmler

Counsel for Plaintiff

Packsheet Tower, Naga City

Roll No. 87432 IBP No. 863992

MCLE Compliance No. 11-00083469