Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

10th Judicial Region
XXX City

XXX CIVIL CASE NO. XXX

Plaintiffs,

-versus-
FOR:
XXX RECOVERY OF
Defendant. POSSESSION
X----------------------------------------------------/

MOTION TO AMEND PRE-TRIAL ORDER

PLAINTIFFS, through the undersigned counsel unto this

Honorable Court most respectfully avers:

1. That on XXX the Pre-Trial Conference for the above

captioned case was conducted;

2. That the undersigned counsel appeared in the scheduled Pre-

Trial Conference but due to conflict of schedule, the counsel
arrived immediately after the case has been called;

3. That the Pre-Trial Order dated XXX was received by the

Plaintiffs through counsel on XXX;

4. That the said Pre-Trial Order enumerates only the Plaintiffs

XXX and XXX as witnesses;

5. That in the interest of justice, Plaintiffs by counsel most

respectfully move for the amendment of Pre-Trial Order to
include additional witnesses vital to prove the allegations in
the complaint. To wit:

a. XXX - To corroborate the statements of XXX and XXX;

b. XXX - To testify:
i. xxx ;
ii. xxx;
 iii. xxx.

6. That the testimony of these witnesses will substantiate the

allegations in the complaint that XXX is a Qualified Farmer
Beneficiary, he is one of the awardees of Certificate of Land
Ownership Award No. XXX and the Plaintiffs are his children
who by law succeeded to his right over the property upon his
death;

7. That the Judicial Affidavit of XXX was already submitted in

Court and Judicial Affidavits of XXX and XXX are hereto
attached;

PRAYER

WHEREFORE, in light of the foregoing premises it is

most respectfully prayed that anew PRE-TRIAL ORDER be issued:

1. Incorporating XXX and XXX as additional witnesses for

the Plaintiff and their Judicial affidavits be marked as
Exhibits “X” and “X” respectively;

2.Giving additional Two (2) trial dates for the Plaintiffs.

Other reliefs deemed just and equitable are likewise

prayed for.

XXXX
[Counsel for the Plaintiff]
Address
Tel. No. XXX| XXX@gmail.com

By:

COUNSEL
Attorneys Roll No. XXX, TIN XXX
IBP (NATIONAL) O.R. XXX, XXX January 20XX
PTR O.R. No. XXX, Malaybalay City, XXX January 20XX
MCLE Cert. No. XXX valid until January 20XX

NOTICE OF HEARING
ATTY. XXX
Counsel for the Defendant
XXX City, Province

GREETINGS!

Please be informed that the foregoing motion will be submitted

for the kind consideration of the Honorable Court sans appearance
and argument. Thank you so much.

XXX

Copy Furnished
XXX
Counsel for the Defendant