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PRE-TRIAL BRIEF
COMES NOW, the DEFENDANT by counsel and to this
Honorable Court, respectfully submits his pre-trial brief containing
the following:
1. Defendant is willing to enter into an amicable settlement
of the case, under the terms and conditions agreeable to
both parties and submit to alternative modes of dispute
resolution;
2. Defendants admits the following facts:
a. Paragraph 2, 3, 4, and 5 of the complaint;
b. Defendant admits that there was a new tax declaration
issued with respect to the tax declaration in the name of
defendant, as stated in paragraph 6 of the complaint, but
DENY for lack of knowledge sufficient to form a belief as to
the truth or falsity that plaintiff attempted to pay real
property tax on January 15, 2014 on the aforesaid
property;
1
5. Witness to be presented:
a. Mr. Pedro dela Cruz, the defendant is willing to take the
stand and become a witness for his cause and to testify on
allegations stated in the complaint and denials in his
Answer;
6. Defendant Reservation:
The Defendant reserves the right to present additional
documentary and testimonial evidence as the exigencies of the
trial may require.
7. Specific Trial Dates:
It is respectfully requested that the trial dates be set during
the pre-trial conference to dates most convenient to this
Honorable Court and to all the parties.
RESPECTFULLY SUBMITTED.
Dagupan City, September 12, 2014.
FRANCISCO-TUPAS-CAYETANO-JUNIO
Counsel for the Defendant
PEDRO DELA CRUZ
9th Floor, Prime Condominium I
989 Dbest Street, Diz Village
9 Makati City, Metro Manila, Philippines
Telephone: (075) 523-4404; (075) 522-4026
Office Mobile: (0932) 864-0684; Fax: (075) 403-3127
Email address: tabithafrancisco@gmail.com
abraham_junio@yahoo.com
TABITHA F. A. FRANCISCO
Notary Public
Until December 31, 2014
PTR No. 987654
Issued on January 3, 2014
Dagupan, Pangasinan
IBP No. 876543, 1-3-14
Atty. Roll No. 98789
ABRAHAM F. JUNIO
Notary Public
Until December 31, 2016
PTR No. 143143
Issued on January 7, 2014
Dagupan, Pangasinan
IBP No. 876543, 1-1231-1
Atty. Roll No. 99323
Copy Furnished:
(By Registered Mail)
ANGELA MERICCI G. MEJIA
Counsel for plaintiff
Juana Dela Cruz
Brgy. Cayanga,
San Fabian, Pangasinan