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PAULO AVELINO,
Plaintiff,
- versus - Civil Case No. 668180
For: Collection of sum of
money
JOHN PALMA,
Defendant
.
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PRE-TRIAL BRIEF
Present evidence to prove that no payment was received on the day of July
16, 2011, coming for the Defendant.
RESERVATION
8.1. Plaintiff respectfully reserves the right to present other witnesses,
documents or evidences in addition to, or in substitution of, those
mentioned above and or for purposes in addition to or in substitution of
those mentioned should a need thereof arises; propose other issues as
the exigencies of trial may demand; cite and invoke other laws and
jurisprudence that may be relevant in the course of the proceedings;
amend his Petition, as may be warranted.
APPROXIMATE NUMBER OF HOURS NEEDED TO COMPLETE THE
PRESENTATION OF EVIDENCE
9.1. Should Defendant refuse to enter into stipulations of fact and make
admissions, Petitioner will need about three (3) hours to complete the
direct examination of its witnesses, at approximately one (1) hour and
thirty (30) minutes per witness. These estimates exclude the time for
the cross and re-direct examinations, which is difficult to predict.
_________________________________
ATTY. ZARIAN LYN A. GASAPO
Counsel for the Plaintiff
XYZ bldg., Iloilo City, Philippines
Roll of Attorney No. 22344
IBP No. 677556 Lifetime/Iloilo City
PTR No. 6011111/1-05-17/Iloilo City
MCLE Compliance No.: 111-0007415