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    Sample Pre-Trial Brief

    Uploaded by

    Gerald
    This document is a pre-trial brief submitted by plaintiffs in a civil case regarding unlawful detainer and damages against defendants for non-payment of rent. It outlines the facts of the case, issues to be resolved including ownership of the property and liability for unpaid rent, witnesses and evidence to be presented, applicable laws, and availability for trial dates.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd

    Sample Pre-Trial Brief

    Uploaded by

    Gerald
    129 views3 pages
    This document is a pre-trial brief submitted by plaintiffs in a civil case regarding unlawful detainer and damages against defendants for non-payment of rent. It outlines the facts of the case, issues to be resolved including ownership of the property and liability for unpaid rent, witnesses and evidence to be presented, applicable laws, and availability for trial dates.

    Original Description:

    Sample Pre-Trial Brief for Unlawful Detainer

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    This document is a pre-trial brief submitted by plaintiffs in a civil case regarding unlawful detainer and damages against defendants for non-payment of rent. It outlines the facts of the case, issues to be resolved including ownership of the property and liability for unpaid rent, witnesses and evidence to be presented, applicable laws, and availability for trial dates.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    129 views3 pages

    Sample Pre-Trial Brief

    Uploaded by

    Gerald
    This document is a pre-trial brief submitted by plaintiffs in a civil case regarding unlawful detainer and damages against defendants for non-payment of rent. It outlines the facts of the case, issues to be resolved including ownership of the property and liability for unpaid rent, witnesses and evidence to be presented, applicable laws, and availability for trial dates.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
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    Republic of the Philippines

    Second Judicial Region


    4th Municipal Circuit Trial Court
    ________________________
    Province of Cagayan

    _________________________,
    Plaintiffs,
    -versus- Civil Case No. _____________
    For: Unlawful Detainer with
    Damages

    ______________________ and all


    persons claiming rights under
    her
    Defendants.
    x---------------------------------x

    PRE-TRIAL BRIEF

    Plaintiffs, __________________, through the undersigned


    counsel, respectfully submit the following Pre-Trial Brief
    pursuant to the Notice of Pre-Trial Conference issued by the
    Honorable Branch Clerk of Court ________________:

    BRIEF STATEMENT OF FACTS/CASE

    1. _______________________________

    PLAINTIFF’S ADMISSION

    2. Complainant has no other facts and circumstances


    to admit other than those already stated in her Complaint filed
    _______________________.

    PROPOSED STIPULATION OF FACTS

    ___________________________________________________________

    POSSIBILITY TO ENTER INTO COMPROMISE AGREEMENT

    3. Herein plaintiffs are willing to discuss the possibility


    of entering into agreement as may be allowed by law under such

    1|Page
    terms and conditions mutually acceptable to all parties
    concerned.

    ISSUES TO BE TRIED / RESOLVED

    4. The issues to be resolved in this case are:

    a) Whether or not the plaintiffs are the registered


    owners of the subject property;

    b) Whether or not defendants only possess the


    subject property as a mere lessee.

    c) Whether or not defendants should vacate the


    subject property due to the non-payment of
    rent.

    d) Whether or not defendants are liable to pay the


    unpaid rentals plus interests, damages and
    attorney’s fees.

    WITNESSES TO BE PRESENTED

    5. Plaintiffs and or their representatives will be


    presented to testify and substantiate the allegations in the
    complaint and likewise to identify the documents to be
    presented in the course of the trial of the case.

    6. _____________________________________________

    MODES OF DISCOVERY

    7. Herein plaintiffs hereby manifest that they are


    considering to avail of the various modes of discovery as
    provided for under the Rules of Court, as they may deem fit and
    necessary during the course of the trial.

    DOCUMENTARY EVIDENCE

    8. Plaintiffs will present the following documents:

    a. ________________________
    b. ________________________
    c. ________________________
    d. ________________________
    e. ________________________

    2|Page
    Furthermore, plaintiffs reserve their right to present
    additional evidence as the need arises or once available.

    APPLICABLE LAWS

    9. Pertinent provisions of the Civil Code Code, Revised


    Rules of Court and existing jurisprudence there under.

    AVAILABLE TRIAL DATES

    10. Plaintiffs’ counsel will be available on such trial dates


    mutually agreed upon during the pre-trial, subject to the
    availability of the Honorable Court’s calendar.

    RESPECTFULLY SUBMITTED.

    ____________________, September 16, 2019.

    ____________________
    Counsel for the Plaintiffs
    11/F Agustin 1 Building, F. Ortigas Jr.Road,
    Ortigas Center, Pasig City.
    E-mail: ___________________
    Roll No. _______________
    PTR NO. _____________________/Pasig City
    IBP LIFETIME NO. _____________/Rizal Chapter
    MCLE Compliance No. _____________
    Valid Until ________________.

    COPY FURNISHED:

    ____________________

    3|Page

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