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Presentation of Direct Testimony (Ex-parte)

I. Entry of Appearance

Lawyer: Good Morning/Afternoon Your Honor, I am Atty. Sarita G. Alvarado, appearing for
the Plaintiff in this case, _______________, represented by its ________________, __________________.
We are ready Your Honor.

Judge: Whats your pleasure?


II. Pending Incident

Lawyer: I would like to proceed with the presentation of evidence ex-parte your honor, on
account of the order granting our motion to declare the Defendant in default issued on
________________. With your permission.

Judge: Proceed.

III. Presentation/Offer of Testimony

Lawyer: For my first witness, I would like to call on ____________________. I would like to offer
her testimony to identify and affirm the due execution and contents of:

1. Her Judicial Affidavit dated ______________.
2. Annexes.

IV. Preliminaries

Clerk: [Oath]

Judge: Your witness.

Lawyer: Kindly state your name and personal circumstances for the record.

V. Direct

Lawyer: Do you remember executing a judicial affidavit in relation to this case?

Witness: Yes.

Lawyer: Im handing you a judicial affidavit, please go over it and tell us the relation of the
judicial affidavit that you just mentioned to this judicial affidavit.

Witness: Its the same.

Lawyer: This affidavit has been signed on top of the name _________. Kindly examine it and
identify whose signature it is.

Witness: Its my signature.

Lawyer: Do you affirm the due execution and contents of this affidavit and that you
answered the questions truthfully?

Witness: Yes.

Lawyer: You made reference to Annex __ on page __. Kindly go over this document and
identify if this is a faithful reproduction of the original.

Witness: Its the same.

Lawyer: I would like to ask, Your Honor for the marking of this evidence as Exhibit A.

Repeat

Lawyer: No further questions. With your permission, I would like to proceed with my next
witness.

V. Closing

Lawyer: With your indulgence, Your Honor, I would like to ask for ten (10) days from today
to file a written formal offer of documentary evidence. After which, I would like to move for
the submission of this case for decision.

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