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Legal Pre-Trial Brief: Case 7080

This document is a pre-trial brief submitted by the plaintiff Nicole Sayson in a civil case against the defendant Jose Napiza for collection of a sum of money. The plaintiff is willing to settle the case through technical experts and admits certain facts in the defendant's answer and sending a demand letter. The plaintiff intends to present a receipt as proof of payment and resort to discovery procedures. The plaintiff will present two witnesses: Mr. AJ Canicosa and plaintiff Nicole Sayson.

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William Santos
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43 views2 pages

Legal Pre-Trial Brief: Case 7080

This document is a pre-trial brief submitted by the plaintiff Nicole Sayson in a civil case against the defendant Jose Napiza for collection of a sum of money. The plaintiff is willing to settle the case through technical experts and admits certain facts in the defendant's answer and sending a demand letter. The plaintiff intends to present a receipt as proof of payment and resort to discovery procedures. The plaintiff will present two witnesses: Mr. AJ Canicosa and plaintiff Nicole Sayson.

Uploaded by

William Santos
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


NATIONAL CAPITAL JUDICIAL REGION
BRANCH 196
LAS PINAS

NICOLE SAYSON
Plaintiff,
Civil Case No. 7080
For: Collection of Sum of Money
-versus-

JOSE NAPIZA
Defendant.
x---------------------------x

PRE-TRIAL BRIEF
PLAINTIFF, by counsel and to this Honorable Court,
respectfully submits this pre-trial brief in compliance with the trial
court’s order dated 1 June 2020, containing the following:
1. Plaintiff is willing to enter into an amicable settlement of the
case, under terms and conditions which are agreeable to
both parties. Plaintiff is willing to submit the technical issues
for resolution by technical experts;

2. Plaintiff admits the following facts:


2.1) the personal circumstances of the parties stated in the
Answer;
2.2) sending of a demand letter dated May 2, 2020;

3. The issues which plaintiff raises are as follows:


3.1) plaintiff’s personality to seek legal relief;
3.2) plaintiff’s entitlement to the amount claimed;
3.3) defendant’s bad faith in filing this suit;

4. Plaintiff intends to present the following documents, in


connection with which the defendant requests from the
plaintiff their admission of their execution and due
authenticity;
4.a) Exhibit 1 – a receipt for the amount of FIVE
HUNDRED THOUSAND PESOS (Php 500,000.00), issued
to defendant, dated May 9, 2020 as proof of payment of
defendant’s obligation;

5. Plaintiff manifests his intention to resort to discovery


procedures;

6. Defendant intends to present the following witnesses:


a) Mr. AJ Canicosa, secretary of the plaintiff.
b) Plaintiff Nicole Sayson, himself.

WHEREFORE, plaintiff prays that the foregoing be taken


cognizance of.
City of Las Pinas, Philippines, June 27, 2020

(Sgd) Atty. William Kyle C. Santos


Counsel For Plaintiff
Unit 1715, ABC Building, Las Pinas City
Roll No: 987654: 5/28/2019
IBP No. 456123:7/1/2019 - Las Pinas
PTR No. 741258:1/1/2020 - Las Pinas

Copy Furnished:
Atty. Timothy Tiletile
Counsel for Defendant
Unit 201 DEF Building, Paranaque City

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