REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
BRANCH 132
CITY OF MAKATI

___________________,
_________________
Plaintiff,

-versus-

_________________ and
JOHN DOE(S),
Def
endants.

PLAINTIFFS PRE-TRIAL BRIEF

PLAINTIFF, by the undersigned counsel, most respectfully

submits this Pre-Trial Brief.

1.0 On the Possibility of Amicable Settlement

Plaintiff is open for discussions on the possibility of having this

case settled amicably if only to avoid prolonged litigation of the case.

2.0 Statement of Plaintiffs Case

This is a case for Sum of Money & Damages. As stated in the

Complaint, ___________________________________________.

3.0 Admissions/Stipulations

Apart from the Plaintiffs allegations of facts in the Complaint,

no further offer of stipulation of facts is deemed necessary.

4.0 Plaintiffs List of Evidence

4.1 Documentary

a. Promissory Note with Chattel Mortgage

b. Certificate of Registration
d. Certificate of Sale
e. Demand Letter
f. Statement of Account
 g. Board Resolution

4.2 Testimonial

Plaintiff will present at least two (2) witnesses who will testify
on and identify the documentary evidence, execution of the
Promissory Note with Chattel Mortgage, Defendants failure to
fail their amortizations, subsequent voluntary surrender of the
subject units and sale, insufficiency of the proceeds of the sale
to cover the outstanding obligation and defendants refusal to
pay their outstanding obligations.

5.0 Proposed Issue to be Resolved

1. Whether or not the Plaintiff is entitled to the sum of

_________________, as and by way of actual damages, with
interest and penalty charges, as stipulated, from
________________ until fully paid, attorneys fees and
liquidated damages.

6.0 Laws and Jurisprudence Involved

a. Pertinent provisions of the Civil Code of the Philippines on

Obligations and Contact, Credit Transactions.

b. Applicable decisions promulgated by the Supreme Court of the

Philippines relative to the facts and issue of the instant case.

7.0 Plaintiffs Reservation

Plaintiff reserves the right to present additional documentary

and testimonial evidence and witnesses, and the right to amend its
pleadings in the course of the trial.

8.0 Available Trial Dates

The undersigned counsel proposes to discuss the trial dates

with the opposing counsel during the pre-trial hearing so as to avoid
conflict of schedules.

Respectfully submitted.

Makati City, ______________________.