SCRIPT:

Barker: All rise, the Honorable Sixto Estudillo presiding. [The judge bangs the gavel
thrice.]

J. Estudillo: Call the cases.

Clerk of Court: No. 1 in the calendar your Honor is the case of Vladimir Putin
Serafin v. Kim Jun Longcop for Recovery of Possession:

J. Estudillo: Counsel for PLaintiff

Atty. Victor: For the plaintiff, your Honor, ready for Pre-Trial.

J. Estudillo: Counsel for defendant

Atty. Whoever: For the defendant, your Honor, ready.

The court notes that both parties had submitted their respective pre-trial briefs

The court then asks for the possibility of amicable settlement, submission of compromise
agreement

Insert script for amicable settlement

J. Estudillo: Atty Victor, may you state your theory of the partys claim?

Atty. Victor recites the theory

J. Estudillo: Atty Melvic, please state your theory of the defendants case.

Atty. Melvic recites theory

J. Estudillo: Atty. Victor, please state your request for stipulations.

Atty. Victor recites proposed admissions/stipulations of facts

(In this instance, we shall decide what facts must be admitted as part of the play,
including conditions precedent, prior repeated demand, jurisdictional facts, etc.)

Example:

Atty. Victor: Your Honor, as stated in our pre-trial brief, we request the following stipulations:

1) That the property in question is registered under the plaintiffs name as

appearing in TCT No. ____________.
 Atty. Melvic: We cannot stipulate on that, your Honor.

Atty. Victor: 2) That a demand letter was sent and received by the Defendant on ___________
as shown in a copy of that demand letter with proof of receipt via registered mail attached to the
demand letter.

Atty. Melvic: Admitted, your Honor.

Atty. Victor: 3) That despite receipt of that demand letter the defendant refused to vacate the
property in issue.

Atty. Melvic: Admitted, your Honor.

Atty. Victor: That will be all for the plaintiff, your Honor.

J. Estudillo: Alright, Atty. Melvic, any proposed stipulations?

Atty. Melvic: Yes, your Honor.

1) That the property has not been offered for sale to the defendant who has the
right of first refusal.

Atty. Victor: Denied, your Honor.

Atty. Melvic; 2) That the defendant is able and willing to purchase the property in question at a
reasonable price.

Atty. Victor: We cannot stipulate on that, your Honor.

Atty. Melvic: That will be all for the defendant, your Honor.

Factual issues asked by Judge

Atty Victor: Your honor, as stated in our pre-trial brief, here are my factual issues:

Atty Victor recites the factual issues and provides evidence to support

J. Estudillo: Alright, please pick your available dates for the marking of your respective
documentary exhibits before the Branch Clerk of Court.

Atty. Victor: May we have October 20, 2017 at 1:30 p.m., your Honor.

Atty. Whoever: Available, your Honor.

Examples:

- On marking of evidence.

J. Estudillo: Atty. Victor, do you tend to adopt the evidence as part of your case?

Atty. Victor: Yes your honor we adopt the evidence as part of our case and request
that it be marked as exhibit 5 for the plaintiff.

- On admission of facts:

Atty Victor: Your honor we admit and stipulate that the Foreshore lease was duly issued
and executed in accordance with law and that it is genuine.

Judge E: Atty. Melvic do you submit to the due execution and genuineness of the
foreshore lease agreement?

Atty Melvic: Yes your honor, we submit to the genuineness and due execution but not
to the contents of said document.