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PRE-TRIAL BRIEF
(for individual defendants)
PARTIES
STATEMENT OF FACTS
5. ALII defaulted in its payments and, in a letter dated February 12, 2006,
invoked the provision in the Promissory Note and Assignment of
Assets/Credits which states that “the proceeds and/or funds of the
Assigned Credits in the event of default shall automatically ceded,
transferred and delivered unto the Lender by virtue of this Assignment
without the necessity of any new writing or execution of any document,
therefore.” ALII endorsed all its credits to People’s Credit.
ISSUES TO BE TRIED
WITNESSES TO BE PRESENTED
Defendants will present the following witnesses:
1. Guillermo R. Soco
2. Adelina O. Soco
3. Inocentes C. Pepito, Jr.
4. Perfecto C. Quijano, Jr.
5. Vicente Go
They will testify as to the nature of the business of ALII, the
contract of loan, surety agreement, and other matters relating to the
claims and defenses of all defendants. Each of their testimonies is
approximated to last for 30 minutes.
A reservation is made to the effect that the defendants will
present additional witnesses as circumstances warrant.
Respectfully submitted.
BY:
FELIPE M. LANDICHO
IBP no. 722945, Cebu City, Jan. 3, 2008
PTR no. 3611841, Cebu City, Jan. 3, 2008
Roll no. 41885
Copy Furnished:
ATTY. LITO A. ALCERA
POSO, SUSUSCO & ALCERA
Collaborating Counsel for the Plaintiff
2nd Accelerando Building,
Sen. Gil J. Puyat Avenue,
Makati City
EXPLANATION
Pursuant to the provisions of Section 11 of Rule 13 of the 1997 Rules of
Civil Procedure, the undersigned counsel of defendants manifests that the filing
and service of the foregoing Pre-trial Brief is being made through registered mail
due to distance, which makes personal filing and service impracticable.
FELIPE M. LANDICHO