Professional Documents
Culture Documents
- versus -
For: Ejectment
RICO YAP,
Defendant.
x----------------------------------- x
PRE-TRIAL BRIEF
III.1
Defendant only admits the facts stated in his Answer, i.e., as to his
personal circumstances, that a Contract of Lease was entered into dated 5
March 2011, receipt of demand to vacate, and his possession of the
property.
III.2
Subject to a concrete proposal for stipulation of additional facts
from plaintiff during pre-trial or even thereafter, defendant admits no other
facts from the Complaint.
IV.
ISSUES TO BE TRIED
IV.1
Defendant submits that the following issues put forward by plaintiff
are subject to proof:
IV.1.1
IV.2
Defendant submits that the following issues he put forward are
subject to proof:
IV.2.1
IV.2.2
Defendants entitlement to the claims made in his
Compulsory Counterclaim;
V.
EVIDENCE
RESORT TO DISCOVERY
VI.1
Considering the relatively simple issues presented, defendant does
not intend to avail of discovery at this time.
VI.2
Subject, however, to a concrete and reasonable request for
discovery from plaintiff, defendant reserved the right to discovery before
trial.
VII.
VII.1
December
December
December
December
December
December
5, 2014
8, 2014
10, 2014
12, 2014
17, 2014
19, 2014
RESPECTFULLY SUBMITTED.
Taguig City; 21 November 2014.