REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
Makati City
Branch 58

Asia Brewery Inc., CIVIL CASE No. 121509

Plaintiff,

- versus- FOR: Damages for

Breach of Contract

Abbie Patricia Fevidal,

Defendant,

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PRE-TRIAL BRIEF

COMES NOW, the defendant, through the undersigned

counsels, and to this Honorable Court, most respectfully submits her
Pre-Trial brief pursuant to the Order of the Court as follows –

STATEMENT OF THE FACTS

 This is a civil case for damages for breach of contract….

AMICABLE SETTLEMENT

The defendant respectfully manifests, without admitting

liability or waiving any of his right or defenses, that she is open to
settling this dispute amicably, subject to a concrete proposal that is fair
and reasonable and a reciprocal manifestation of openness from the
plaintiff.

ADMISSIONS

PROPOSALS AND STIPULATIONS

ISSUES

DOCUMENTARY EVIDENCE FOR MARKINGS

1. Affidavit of the defendant – Exhibit “A”

This is a sworn statement of the defendant, Abbie Patrcia

Fevidal to prove

2. Affidavit of ….
3.
 WITNESSESES TO BE PRESENTED

1. Abbie Patricia Fevidal –

2.

The defendant reserves the right to present other evidence that

may become necessary during the trial.

AVAILABLE TRIAL DATES

Defendant requests that the available trial dates be set in

agreement with the court calendar and that of the respective counsels
on the date set by the Court during the Pre-trial.

PRAYER

Wherefore, premises considered, it is respectfully prayed the

foregoing Pre-Trial brief be admitted.

All other reliefs just and equitable are prayed for.

Respectfully Submitted.

Makati City. January 30, 2019.

 DGP LAW

Counsel for the Plaintiff

Unit 11-I, V. Madrigal Building

6793 Ayala Avenue, Makati City 1226

Tel. No. 4537644; Fax No. 9021777

By:

ALEXIS D. DELA CRUZ

Roll No. 278923, 4/29/2014

IBP Lifetime Member No. 6701

IBP Makati Chapter

PTR 6921123, 1/7/2023, Makati City

MCLE Compliance No. IV-0985,

2/7/2018

RALYANA KNUSHARA M.
GADDI

Roll No. 230948, 4/29/2014

 IBP Lifetime Member No. 8911

IBP Makati Chapter

PTR 2019345, 1/7/2023, Makati City

MCLE Compliance No. IV-1244,

2/7/2018

AZANITH ANN B. PAYAD

Roll No. 2158337, 4/29/2014

IBP Lifetime Member No. 1078

IBP Makati Chapter

PTR 1158337, 1/7/2023, Makati City

MCLE Compliance No. IV-8977,

2/7/2018

CC: PAUMIG & VELUYA LAW OFFICES

Counsel for the Plaintiff

Unit 15, The Empire Towers,

Chino Roces Ave., Makati City 1215

Tel. No. 2103745; Fax No. 9021006

 EXPLANATION OF SERVICE

Copy of the Motion for Leave of Court to file Third-Party

Complaint was served to Plaintiff’s counsel by registered mail due to
time constraints and distance, and for lack of the undersigned’s staff
who can serve the same in person.

ALEXIS D. DELA CRUZ

RALYANA KNUSHARA M. GADDI

AZANITH ANN B. PAYAD