Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

Branch 2
Dumaguete City

_______________________________
Plaintiff,

Civil Case No.

- versus -

________________________________
Defendants,
x - - - - - - - - - - - - - - - - - - - - - - - - - -----x

PRE-TRIAL BRIEF

Plaintiff, through counsel, to this Honorable Court, respectfully submits this Pre-
trial Brief as follows -

A. STATEMENT OF FACTS AND CASE

This is a complaint for

B. WILLINGNESS TO ENTER INTO AMICABLE SETTLEMENT

Plaintiffs are open to settlement provided it is on just and reasonable grounds.

C. ADMITTED FACTS

All allegations indicated in the pleadings submitted by the plaintiff.

D. PROPOSED STIPULATIONS OF FACTS

As provided under Rule 26 of the Rule on Civil Procedure, Plaintiff requests

defendant to admit the genuineness and due execution of the following documents within
fifteen (15) days after service thereof, otherwise each of the following documents shall be
deemed admitted:

POSED ISSUES TO BE RESOLVED

E
.
Whether or not
P
R
O
Whether or not
 Whether or not plaintiff

F. TESTIMONIAL EVIDENCE

Plaintiff intend to present one (1) or two (2) witnesses to prove plaintiff's
allegations and claims set forth in the complain.

G. DOCUMENTARY EVIDENCE

Plaintiffs request the marking as exhibits of the following documents:

1.) (Exhibit "A")

2.) (Exhibit "B")
3.) (Exhibit "C")

H. AVAILMENT OF MODES OF DISCOVERY

Plaintiffs reserve the right to avail of the modes of discovery in addition to the
aforementioned request for stipulation.

I. APPLICABLE LAWS AND JURISPRUDENCE

The Plaintiffs grounds its claims on the provision of the ( sample ,New Civil Code and
1997
Rules on Civil Procedure. )

J. POSSIBILITY OF AMICABLE SETTLEMENT

Plaintiffs are amenable to a reasonable settlement.

K. RESERVATION

Plaintiffs respectfully reserve the right to present additional oral and documentary
evidence as may become necessary in the course of the trial.
 L. SPECIFIC TRIAL DATES
It is respectfully requested that the trial dates be set during the pre-trial conference to dates

most convenient to this Honorable Court and to all the parties.

Respectfully submitted.
December 8, 2025, Dgte City.

ATTY. Name
Counsel for Plaintiff
Court and PAO Building
123 street, Brgy. Bagacay , Dgte City
PTR No. 012345; 01/15/2025; Dgte City
IBP Lifetime No.551986; 01-25-25; Pasig City
Roll of Attorney's No.
MCLE Compliance No.
Tel. (fax) no.
Email:

Copy Furnished:

Municipal Trial Court

Branch 2
DGTE City

Atty.
Counsel for the Defendant
Complete address

EXPLANATION

Copies of the foregoing Brief were served to defendant's counsel through registered
special mail considering the distance between the address of defendant's counsel and the
undersigned counsel. Moreover, the office of the undersigned has no personnel to effect
personal service to the defendants.

Server name: