Anda di halaman 1dari 2

Republic of the Philippines

NATONAL CAPTAL JUDCAL REGON


REGONAL TRAL COURT
City of Manila~Branch 90
DEMME R. ROMERO
Plaintiff,
Civil Case No. 97-14344
- versus -


MARA F. GUAN
Defendant.
x ------------------------------------- x


PRE-TRAL BREF

PLANTFF, by counsel, respectfully submits her Pre-Trial Brief, as follows:


. BREF STATEMENT OF CLAMS

1.1. Plaintiff seeks principally to recover the amount of five hundred thousand
pesos (P500,000.00), with legal interest, as actual damages and sixty thousand pesos
(P60,000.00) as Attorney's Fees, arising from failure or to pay the aforementioned
amount to plaintiff despite repeated demands.

. SSUES TO BE TRED

2.1. Whether or not the plaintiff is entitle to the amount claimed.



. EVDENCE

3.1 Plaintiff intends to present the following witnesses:

3.1.1. Plaintiff herself, who will testify on the true circumstances leading
to the filing of this suit against her;

3.1.2. An employee of Fermin Enterprises with personal knowledge as to
the true circumstances behind the alleged obligations due and owing in favor of
plaintiff.

3.2 Plaintiff reserves the right to present any and all documentary evidence which shall
become relevant in the course of trial as well as any other witnesses whose testimony will
become relevant to belie plaintiff's witnesses, if necessary.


V. RESORT TO DSCOVERY

6.1. Considering the relatively simple issues presented, plaintiff does not intend to avail
of discovery at this time.

6.2. Subject, however, to a concrete and reasonable request for discovery from plaintiff,
defendant reserves the right to resort to discovery before trial.

RESPECTFULLY SUBMTTED.

City of Manila; November 21 2011.


(SGD.) DOREEN GRACE R. FERMN
Counsel for Plaintiff

Copy furnished:

ATTY. KEALA BLEZA
Counsel for Defendant