REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

SEVENTH JUDICIAL REGION
BRANCH 1
CEBU CITY

KENDRICK LAMAR
Plaintiff

-versus- CIVIL CASE No. 0001

For: Collection Sum of
Money

BRUNO MARS
Defendant
x-----------------------------------------------------------------------------------------x

PRE-TRIAL BRIEF

COMES NOW, the defendant by the undersigned counsel and to this

Honorable Court, respectfully submits this pre-trial brief in compliance with
the trial court’s order dated 31 January 2018, containing the following:

Defendant is willing to enter into an amicable settlement of the case,

under the terms and conditions which are agreeable to both parties. Defendant
is willing to submit the technical issues for resolution by technical experts;

II

Defendant admits the following facts:

a) The personal circumstances of the parties stated in the Answer;

b) The receipt of a demand letter dated June 14, 2017.

III

The issues which the defendant raises are as follows:

1. Plaintiff’s personality to seek legal relief;

2. Plaintiff’s entitlement to the amount claimed;
3. Plaintiff’s bad faith in filing the suit;
4. Defendant’s entitlement to the claims made in his compulsory
counterclaim as a result of plaintiff’s bad faith;
 IV

Defendant intends to present the following documents, in connection

with which the defendant’s requests from plaintiff their admission of their
execution and due authenticity:

Exhibit 1 – a receipt for the amount of twenty thousand pesos (Php

20,000.00) issued to defendant, dated July 5, 2017 as proof of payment
of defendant’s obligation

Exhibit 2 – a receipt for the amount of forty thousand pesos (Php

40,000.00) issued to defendant dated September 7, 2017 as proof of
payment of defendant’s obligation.

Defendant manifests his intention to resort to discovery procedures;

VI

Defendant does not intend to amend his answer;

VII.

Defendant intends to present the following witnesses:

a) Mr. Shawn Carter, secretary of plaintiff
b) Defendant Bruno Mars, himself

WHEREFORE, defendant prays that the foregoing be taken cognizance

of.

City of Cebu, Philippines. February 6, 2018

ATTY. ELLA MARIJA LANI-YELICH

Counsel for Defendant
Room 4, 5th floor, Avengers Towers,
Cebu Business Park, Cebu City, Philippines.
IBP No. 123456; 01/10/18 - Cebu
PTR No. 1234567; 01/10/18 – Cebu
Roll No. 12345; 05/21/15
MCLE No. V – 00222111; 09/09/17
Copy furnished:

By personal service, to:

ATTY. DONALD GAMBINO

Counsel for Plaintiff
#88 Oakland Avenue, Cebu City, Cebu
Republic of the Philippines) S. S
City of Cebu )

AFFIDAVIT OF SERVICE

I, JACK ANTONOFF, Filipino, of legal age, married and resident of

Cebu City after having been sworn in accordance with law, hereby depose and
state that:

1. I am a paralegal of the LANI AND ASSOCIATES LAW OFFICE,

with office address at Room 4, 5th floor, Avengers Towers, Cebu
Business Park, Cebu City, Philippines.

2. On February 2, 2018 I personally delivered and served copies of the

Pre-trial Brief upon the counsel of plaintiff to the respective office
addresses as indicated below:

ATTY. DONALD GAMBINO

Counsel for Plaintiff
#88 Oakland Avenue, Cebu City, Cebu

Received By: Bruce Banner

Received On; February 2, 2018

I am executing this Affidavit of Service to attest to the truth of the

foregoing facts and for any legal purposes it may serve.

IN WITNESS WHEREOF, I have hereunto set my hand this 29th day

of January 2018 in Cebu City, Philippines.

JACK ANTONOFF
Affiant

BEFORE ME, this 2nd day of February 2018 in the City of Cebu
personally appeared JACK ANTONOFF, and presented to me his Philippine
Passport No. EB8868190 issued by Department of Foreign Affairs Cebu on
January 2, 2016 valid until January 2, 2021, who executed the foregoing
instrument, and acknowledged that the same are their free act and deed.

WITNESS MY HAND AND SEAL this 2nd day of February, 2018 in

Cebu City, Cebu.
 ATTY. ELLA MARIJA LANI-YELICH
Notary Public for Cebu City, San Fernando, Carcar,
Room 4, 5th floor, Avengers Towers, Cebu Business
Park, Cebu City, Philippines.
Appointment No. 123, until Dec. 31, 2018
IBP No. 488130, Cebu City, 01/03/18
PTR No. 268913, Cebu City, 01/04/18
Roll No. 51030
TIN No. 123-988-555
MCLE No. V- 00222111; 9/09/17

Doc. No. 7;
Page No. 11;
Book No. 1;
Series of 2018