REPUBLIC OF THE PHILIPPINES
NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
Makati City
Branch 58
Asia Brewery Inc., CIVIL CASE No. 121509
Plaintiff,
- versus- FOR: Damages for
Breach of Contract
Abbie Patricia Fevidal,
Defendant,
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PRE-TRIAL BRIEF
COMES NOW, the defendant, through the undersigned
counsels, and to this Honorable Court, most respectfully submits her
Pre-Trial brief pursuant to the Order of the Court as follows –
STATEMENT OF THE FACTS
This is a civil case for damages for breach of contract….
AMICABLE SETTLEMENT
The defendant respectfully manifests, without admitting
liability or waiving any of his right or defenses, that she is open to
settling this dispute amicably, subject to a concrete proposal that is fair
and reasonable and a reciprocal manifestation of openness from the
plaintiff.
ADMISSIONS
PROPOSALS AND STIPULATIONS
ISSUES
DOCUMENTARY EVIDENCE FOR MARKINGS
1. Affidavit of the defendant – Exhibit “A”
This is a sworn statement of the defendant, Abbie Patrcia
Fevidal to prove
2. Affidavit of ….
3.
WITNESSESES TO BE PRESENTED
1. Abbie Patricia Fevidal –
2.
The defendant reserves the right to present other evidence that
may become necessary during the trial.
AVAILABLE TRIAL DATES
Defendant requests that the available trial dates be set in
agreement with the court calendar and that of the respective counsels
on the date set by the Court during the Pre-trial.
PRAYER
Wherefore, premises considered, it is respectfully prayed the
foregoing Pre-Trial brief be admitted.
All other reliefs just and equitable are prayed for.
Respectfully Submitted.
Makati City. January 30, 2019.
DGP LAW
Counsel for the Plaintiff
Unit 11-I, V. Madrigal Building
6793 Ayala Avenue, Makati City 1226
Tel. No. 4537644; Fax No. 9021777
By:
ALEXIS D. DELA CRUZ
Roll No. 278923, 4/29/2014
IBP Lifetime Member No. 6701
IBP Makati Chapter
PTR 6921123, 1/7/2023, Makati City
MCLE Compliance No. IV-0985,
2/7/2018
RALYANA KNUSHARA M.
GADDI
Roll No. 230948, 4/29/2014
IBP Lifetime Member No. 8911
IBP Makati Chapter
PTR 2019345, 1/7/2023, Makati City
MCLE Compliance No. IV-1244,
2/7/2018
AZANITH ANN B. PAYAD
Roll No. 2158337, 4/29/2014
IBP Lifetime Member No. 1078
IBP Makati Chapter
PTR 1158337, 1/7/2023, Makati City
MCLE Compliance No. IV-8977,
2/7/2018
CC: PAUMIG & VELUYA LAW OFFICES
Counsel for the Plaintiff
Unit 15, The Empire Towers,
Chino Roces Ave., Makati City 1215
Tel. No. 2103745; Fax No. 9021006
EXPLANATION OF SERVICE
Copy of the Motion for Leave of Court to file Third-Party
Complaint was served to Plaintiff’s counsel by registered mail due to
time constraints and distance, and for lack of the undersigned’s staff
who can serve the same in person.
ALEXIS D. DELA CRUZ
RALYANA KNUSHARA M. GADDI
AZANITH ANN B. PAYAD