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Republic of the Philippines

__th Judicial Region


MUNICIPAL TRIAL COURT
Branch __, __________

THE PEOPLE OF THE PHILIPPINES, Criminal Case No. ________


Plaintiff,

-versus- -for-

______________________________ ______________________
Accused.
x--------------------------------------------------------x

PRE-TRIAL BRIEF FOR THE ACCUSED

ACCUSED, through the undersigned counsel, before this Honorable Court,


most respectfully submit this Pre-Trial Brief:

POSSIBILITY OF PLEA BARGAINING


OR PLEA TO A LESSER OFFENSE

None.

SUMMARY OF ADMITTED FACTS


AND PROPOSED STIPULATION OF FACTS

The Accused admits the identity of the person charged in the information
and that of the person arraigned is one and the same.

EVIDENCE FOR MARKING

1. _______________________________ – Exhibit “1”


2. _______________________________ – Exhibit “2”

The Accused reserves to adopt prosecution’s evidence whenever favorable


to the Accused.

ISSUE

Whether the accused committed the offense charged


WITNESSES

1. __________________
2. __________________

TRIAL DATES:

Respectfully submitted.
Place. Date.

NAME OF COUNSEL
Roll No. __________
PTR No. __________, Place and date of issue.
IBP O.R. No. __________, Place and date of issue.
MCLE Compliance No. __________, date

Copy furnished:

Trial Prosecutor

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