Professional Documents
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AAAA,
Plaintiff,
I - DEFENDANTS CLAIM
II - ADMISSION
III - ISSUES
V - DOCUMENTS TO BE PRESENTED
Defendants will identify authenticate and mark their documentary exhibits in the
course of the pre-trial.
RESPECTFULLY SUBMITTED.
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Public Attorney II
Cc:
Atty. x44
_______________________
Republic of the Philippines
MUNICIPAL TRIAL COURT IN CITIES
5th Judicial Region
Branch ___,
Naga City
AAAA,
Plaintiff,
PRE-TRIAL BRIEF
WITNESS
Plaintiff and others who have personal knowledge about the _________________.
STIPULATION OF FACTS
The identity of the parties and that plaintiff will make their proposal and
counter-proposals in open court and admit those already pleaded in the pleadings and
make reservation of any issues that may come out in the course of the Pre-trial
Proceedings and trial proper.
DOCUMENTS
Those attached to the pleadings and other reserves which will be presented in
the course of the proceedings.
RESPECTFULLY SUBMITTED.
By:
___________________
Counsel for the Plaintiff
Cc:
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REPUBLIC OF THE PHILIPPINES
MUNICIPAL CIRCUIT TRIAL COURT
________________
Camarines Sur
_________________,
Plaintiff,
CIVIL CASE No. _______
-versus- FOR: _______________
__________________,
Defendants.
x-----------------------------------x
REPLY
COMES NOW, the plaintiff, through the undersigned counsel and unto this
Honorable Court, most avers:
3. That Paragraphs ___, ___, ___ and ___ of defendants Special Affirmative
defenses are specifically denied, as they are far-fetched conclusions and
convenient inventions of the defendants to suit their own purposes, the
real truth of the whole matter being those that are alleged in the
complaint;
_________________________
Counsel for the Plaintiff