REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

7TH JUDICIAL REGION
BRANCH 77
CARCAR CITY, CEBU

,
Complainant-Appellant
Plaintiffs,
For: PARTITION and
ACCOUNTING with
-versus-
DAMAGES

Defendants.

x------------------------------------x
MOTION TO ADMIT
AMENDED PRE-TRIAL BRIEF

Plaintiffs, by counsel, respectfully state:

1. On 7 December 2018, Plaintiffs timely filed their Pre-

Trial Brief of even date to the Honorable Court RTC, Branch
7.

2. Due, however, to extremely heavy volume of work,

undersigned counsel inadvertently overlooked the sequence
of the Exhibits, thus, resulting to the scrambling of the
Exhibit markings. As well as, the details of the Exhibits such
as the dates and receipt numbers.

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3. In view thereof, Plaintiffs most respectfully and humbly
beg the indulgence of this Honorable Court and pray that the
attached Amended Pre-Trial Brief be admitted into the
records of the instant case to avoid any confusion.

4. This Motion is filed in good faith.

PRAYER

WHEREFORE, premises considered, Plaintiffs respectfully

pray that this Honorable Court ADMITS the attached
Amended Pre-Trial Brief into the records of the instant case.

Plaintiffs also pray for other just and equitable reliefs. x

City for y City. 20 June 2019.

copy furnished:

NOTICE OF HEARING

Please submit - and take notice of - the foregoing Motion for

the consideration of the Honorable Court immediately upon
receipt thereof without further need of appearance of counsel.

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 EXPLANATION

The undersigned caused the service of the foregoing Motion

by registered mail due to distance and time constraints.

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