REPUBLIC OF THE PHILIPPINES
JUDICIAL REGION
                               TRIAL COURT
                             BRANCH -----CITY
NAME,
                      Plaintiff,
       -vs-                                       Civil Case No. ______
                                                  For: Sum of Money
NAME,
                      Defendant.
x---------------------------------------------x
                   PRE-TRIAL BRIEF OF THE DEFENDANT
      DEFENDANT, by counsel, respectfully submits this Pre-Trial Brief
and states:
                 POSSIBILITY OF AMICABLE SETTLEMENT
      Defendant is willing to submit to alternative modes of dispute
resolution and to enter into an amicable settlement of the case, under
reasonable terms and conditions acceptable to both parties.
                             STIPULATION OF FACTS
     Defendant limits its admission to those mentioned in its Answer
and proposes for admission by the plaintiff the return of ---------
deductible from the account of the defendant.
                                         ISSUE
   1. Whether or not the plaintiff has a cause of action in the instant
      case;
   2. Whether or not the obligation being demanded by plaintiff exists
      or has been extinguished.
                                     WITNESSES
      _______ will testify on the material allegations in the defendants
answer and identify pertinent documents. Defendant reserves the right
to present any other witnesses whose testimony will become relevant to
belie plaintiffs averments.
                   DOCUMENTS TO BE PRESENTED
      Defendant will present the following documents as evidence:
   a. The Secretarys Certificate granting the authority to _____ for
      purposes of this case.
   b. The Pictures depicting the ______
   c. The Copy of the Inventory of the --------.
   d. Copies of Complaint Affidavit for theft and estafa against the
      defendants employees.
       Defendant reserves the right to present other documents which
shall become relevant in the course of trial.
                          APPLICABLE LAWS
      The New Civil Code of the Philippines provisions on Obligation
and Contracts, Sales, the Rules of Court as well as relevant
jurisprudence.
                             TRIAL DATES
      The dates that may be agreed upon by the parties and convenient
to the calendar of this Honorable Court.
      WHEREFORE, defendant respectfully prays that submission of
this Pre-Trial Brief be noted.
      Respectfully submitted.
      Lipa City, Date
                                   OFFICE
                          Law and Notarial Offices
                          Counsel for the Defendant
            By:
                             LAWYER
                    Roll of Attorneys No. ----
                            PTR No. ---
                            IBP No. ---
            MCLE Compliance No. V-0015499; 3/11/2016
Copy Furnished:
NAme
Address
                            EXPLANATION
       This Pre-Trial Brief is being served to the other party and filed
with the Honorable Court by registered mail, personal mode of service
being impracticable due to distance involved and lack of personnel to
effect the same.
                                                Lawyer