Republic of the Philippines

SEVENTH JUDICIAL REGION

REGIONAL TRIAL COURT
Branch 2 Iloilo City
Juan Ilok,
Plaintiff,
- versus -

Civil Case No. 4292324

For: Collection of sum of money

Brad Armpit,
Defendant.
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PRE-TRIAL BRIEF
DEFENDANT, by counsel, respectfully submits his Pre-Trial Brief, as follows:
1. POSSIBILITY TO ENTER INTO AN AMICABLE SETTLEMENT
a. Subject to a concrete proposal that is fair and reasonable and a reciprocal
manifestation of openness from defendant, plaintiff is open to settling this dispute
amicably,
b. Plaintiff respectfully submits that the desired terms of any amicable
settlement would involve, first, an admission of amount due and owing to plaintiff
and, second, a schedule of payment.
2. STATEMENT OF CLAIMS AND DEFENSES
a. Defendant failed to pay the remaining balance for his indebtedness
amounting to FIFTY THOUSAND PESOS (Php 50,000.00) for the money borrowed by
the defendant.
b. Defendant claims that the amount of FIFTY THOUSAND PESOS (Php
50,000.00) had been paid.
3. MATTERS ADMITTED
a. Defendant admits only those facts stated in their Answer.
4. ISSUES TO BE TRIED
a. Plaintiff submits that the following issue is subject to proof:
a1. The defendant failed to pay the remaining balance of FIFTY
THOUSAND PESOS,
b. Defendant submits that the following issues are subject to proof:

b1. Plaintiff has received the total amount of ONE HUNDRED

THOUSAND PESOS;

5. EVIDENCE
a. Plaintiff intends to present the following witnesses:
a1. Mr. Pedro Siponon, to establish that the plaintiff and defendant
actually met at the place of the plaintiff, that the money owed was given to
the defendant in the amount of FIFTY THOUSAND PESOS;
a2. Ms. Jose Kogmohon, friend of the plaintiff and defendant, as
witness to the transaction;
6. RESORT TO DISCOVERY
a. Considering the relatively simple issues presented, plaintiff does not intend
to avail of discovery at this time;
b. Subject, however, to a concrete and reasonable request for discovery from
defendant, plaintiff reserves the right to resort to discovery before trial.
7. AVAILABLE TRIAL DATES
January 23, 2008, January 30, 2008;
RESPECTFULLY SUBMITTED. Iloilo City. 2 March 2015.

ATTY. PHILLIP OWEN T. BINAYAS

IBP No. 61240
PTR No. 3570896
Roll No. 67325 MCLE V-1110328
TIN No. 540-795-284.