Republic of the Philippines

First Judicial Region

REGIONAL TRIAL COURT
Branch ____
Baguio City

KRIMZY DOODLE.,
Plaintiff CIVIL CASE No. _______

- versus - FOR:
Sum of Money
RASTAFARI MAN.
Defendant

PRE-TRIAL BRIEF

COMES NOW, the DEFENDANT, through the undersigned counsel and unto
the Honorable Court, most respectfully submits his Pre-Trial Brief pursuant to
the Order of the Court and avers:

I. POSSIBILITY OF AMICABLE SETTLEMENT:

Plaintiff is willing to enter into an amicable settlement with the Defendant,

subject to a concrete proposal that is fair and reasonable and a reciprocal
manifestation of openness from defendant.

II. STATEMENT OF DEFENDANT’S DEFENSE

Defendant raises as a defense that the obligation has not yet become due and
demandable on the ground of the extension of period granted by the Plaintiff.

III. PROPOSED STIPULATION OF FACTS

a. The Defendant, on July 8, 2018, obtained a loan from Plaintiff a sum of

money amounting to Five Hundred Thousand Pesos (Php500,000.00)
with an agreed interest of one percent (1%) per month due on July 8,
2019.

b. Before the expiration of the term of the obligation, Plaintiff granted

Defendant an extension of five (5) months for the payment of the debt,
or up until December 8, 2019.

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 IV. ISSUES

Defendant submits that the following issue is subject to proof: The

obligation has not yet become due and demandable because the Plaintiff
granted an extension of five (5) months for the payment of the debt.

V. LIST OF EXHIBITS

a. EXHIBIT “1” – An image of the conversation through text message

between Plaintiff and Defendant granting the five months extension of
the term of the loan.

PURPOSE: To prove that the Plaintiff has extended the period of

payment of the loan.

b. EXHIBIT “2” – Judicial Affidavit of Julie P. Man narrating the

personal meeting of the Plaintiff and the Defendant wherein Plaintiff
granted the extension of the loan.

PURPOSE: To prove that the Plaintiff and Defendant actually met for
the grant of the extension of the loan

c. EXHIBIT “3” – Judicial Affidavit of Rastafari Man narrating the grant

of loan to defendant by the plaintiff and the subsequent extension by
the plaintiff of the payment of the loan.

PURPOSE: To prove that defendant was granted by the plaintiff an

extension for the payment of the loan, hence it has not yet become due
and demandable.

VI. WITNESSES TO BE PRESENTED

a. Julie P. Man

VII. RESORT TO DISCOVERY

Considering the relatively simple issues presented, plaintiff does not intend to
avail of discovery at this time. Subject, however, to a concrete and reasonable
request for discovery from defendant, plaintiff reserves the right to resort to
discovery before trial.

VIII. TRIAL DATES

November 25, 2019 and November 28, 2019

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 PRAYER

WHEREFORE, in view of all the foregoing, Defendant through the

undersigned counsel respectfully prays that the Court note this pre-trial brief.

Baguio City, Philippines, this 8th day of November 2019.

Atty. Lana Baja

Counsel for Defendant
Baja Law Office, Baguio City
PTR No. 1234567; 5/17/2020; Baguio City
IBP No. 2345678; 8/03/2020; Baguio City
Roll of Attorney’s No. 3456789
MCLE No. 45678

Copy furnished thru personal service:

Atty. Yamyam B. Squared

Squared Law Office, Baguio City

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