Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

5th Judicial Region
Branch ____,
Naga City

AAAA,
Plaintiff,

- versus - Civil Case No. 19XX

For: ________________________
BBBB.,
Defendant.
x- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - x

DEFENDANTS PRE-TRIAL BRIEF

Defendant, by undersigned Counsel, unto this Honorable Court, respectfully

submits his Pre-Trial Brief and aver;

I - DEFENDANTS CLAIM

That the _________________________________________________.

II - ADMISSION

Defendant submit the ______________________________________.

III - ISSUES

The issues in this case are:

a. WHETHER THE PLAINTIFF HAS A CAUSE OF ACTION AGAINST

THE DEFENDANT.

b. WHETHER PLAINTRIFF IS LIABLE FOR DAMAGES.

c. WHETHER OR NOT __________________________

IV - NUMBER OF WITNESSES TO BE PRESENTED

 Defendant will present at least _________ witnesses.

V - DOCUMENTS TO BE PRESENTED

Defendants will identify authenticate and mark their documentary exhibits in the
course of the pre-trial.

WHEREFORE, it is respectfully prayed that this Pre-Trial Brief be noted and

made of record.

RESPECTFULLY SUBMITTED.

Naga City, _________________________.

wwwwyyyyyzzzzzzzz
Public Attorney II

Cc:
Atty. x44
_______________________
 Republic of the Philippines
MUNICIPAL TRIAL COURT IN CITIES
5th Judicial Region
Branch ___,
Naga City

AAAA,
Plaintiff,

- versus - Civil Case No. 19XX

For: _________________
BBBB.,
Defendant.
x- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - x

PRE-TRIAL BRIEF

PLAINTIFF, by counsel respectfully submits his Pre-Trial Brief, as follows:

STATEMENT OF PLAINTIFF'S CLAIM

Plaintiff is the ___________________________________________________.

The reality in this case is that __________________________________________..

POSSIBILITY OF AMICABLE SETTLEMENT

Plaintiff is willing to consider any reasonable settlement proposal from the

defendant.

WITNESS

Plaintiff and others who have personal knowledge about the _________________.
 STIPULATION OF FACTS

The identity of the parties and that plaintiff will make their proposal and
counter-proposals in open court and admit those already pleaded in the pleadings and
make reservation of any issues that may come out in the course of the Pre-trial
Proceedings and trial proper.

DOCUMENTS

Those attached to the pleadings and other reserves which will be presented in
the course of the proceedings.

RESPECTFULLY SUBMITTED.

Naga City, ______________________.

By:

___________________
Counsel for the Plaintiff

Cc:
wwwwwxxxxxyyyyzzzzz
 REPUBLIC OF THE PHILIPPINES
MUNICIPAL CIRCUIT TRIAL COURT
________________
Camarines Sur

_________________,
Plaintiff,
CIVIL CASE No. _______
-versus- FOR: _______________

__________________,
Defendants.
x-----------------------------------x

REPLY

COMES NOW, the plaintiff, through the undersigned counsel and unto this
Honorable Court, most avers:

1. That the plaintiff denies the allegation of the defendants in Paragraph _

the truth being that _____________________________________;

2. That plaintiff specifically denies the allegations in paragraph __ and __

the fact being that the defendant ___________________________;

3. That Paragraphs ___, ___, ___ and ___ of defendants Special Affirmative
defenses are specifically denied, as they are far-fetched conclusions and
convenient inventions of the defendants to suit their own purposes, the
real truth of the whole matter being those that are alleged in the
complaint;

WHEREFORE, it is most respectfully prayed that the answer and

affirmative defenses of the defendants be denied and overruled with costs against
the defendants and the prayer in the complaint be granted with such other reliefs
and favorable pronouncements in favor of the plaintiff that may be deemed just,
proper and equitable.

Naga City, ______________.

_________________________
Counsel for the Plaintiff