Republic of the Philippines

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
Quezon City
Branch 76

SANSA STARK and

DAENERYS STARK TARGARYEN,
Plaintiffs,

-versus- CIVIL CASE No. 0602

For: RECONVEYANCE AND
DECLARATION OF NULLITY OF
EXTRA - JUDICIAL SETTLEMENT OF
ESTATE, SPECIAL POWER OF
ATTORNEY AND DEED OF
ABSOLUTE SALE AND DAMAGES

ARYA STARK and AD VENTURES,

Defendants.
x--------------------------------------------------x

PRE-TRIAL BRIEF FOR THE

DEFENDANT

COMES NOW, defendant ARYA STARK by the undersigned counsel, unto

the Honorable Court, most respectfully submits this Pre -Trial Brief, as follows:

POSSIBILITY OF AMICABLE SETTLEMENT

OR ALTERNATIVE MODES OF SETTLING THE CASE

The defendant is open to amicable settlement and other modes of settling

the case.

SUMMARY OF ADMITTED FACTS AND

PROPOSED STIPULATION OF FACTS

Those admitted during the preliminary conference such as identity of parties

and subject matter of the case.
 ISSUES TO BE TRIED OR RESOLVED

WHETHER OR NOT THE SPECIAL POWER OF ATTORNEY IS VALID OR

NOT.

WHETHER THE DISPOSITION OF THE PROPERTY IS VALID OR NOT.

WHETHER OR NOT THE COURT HAS JURISDICTION TO TRY THE CASE.

DOCUMENTS OR EXHIBITS TO BE PRESENTED

1. Special Power of Attorney

2. Extra-judicial Settlement
3. Deed of Sale
4. Other reserved documents

MANIFESTATION AS TO DISCOVERY PROCEDURES

AND REFERRAL TO COMMISSIONERS

The defendant is willing to submit the matter to a commissioner for the

speedy disposition of the case.

WITNESSES AND THE ABSTRACT OF

THEIR TESTIMONIES

The defendant will testify as to his defense as mentioned in the answer. Other
reserved witnesses will testify to corroborate the testimony of the defendant.

PRAYER

It is most respectfully prayed unto the Honorable Court that this Pre-Trial
Brief be noted and be made an integral part of the records of the case.

Respectfully submitted.

Ligao City, Albay, Philippines May 11, 2011

VARGAS AND SURTIDA LAW OFFICE

6 th Floor Citi Center, Poblacion,
Makati City
Tel. Nos.: (02) 4801092; (02) 4801093

By:

ATTY.JOSE POCHOLO R. DEL ROSARIO

Roll Number 10219
IBP No. 030316, 03 March 2011, PPLM
PTR No. 9876543, 03-03-11, Makati City
MCLE Certificate of Compliance No. III-
0001092; 02 Feb 2010
Copy furnished by registered mail.

ATTY. WILLIAM B. BALAYO

913 Riosa St. Tabaco City, Albay

ATTY. JOSE POCHOLO R. DEL ROSARIO

VARGAS AND SURTIDA LAW OFFICE
6 th Floor Citi Center, Poblacion,
Makati City