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BENNY BILANG
Plaintiff,
-versus-
LUCKY T. TINIO
Defendant.
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PRE-TRIAL BRIEF
PLAINTIFF, by counsel, respectfully submits his PRE-TRIAL BRIEF, as
follows:
I.
II.
SUMMARY OF
ADMITTED
STIPULATION OF FACTS
FACTS
AND
PROPOSED
other purposes, the LESSOR shall have the right to rescind this
contract without prejudice to its other rights under the law;
5) That on October 15, 2014, Plaintiff went to the leased premises only
to discover that sacks of rice was stored in the first-storey of the
house;
6) That after his discovery, the Plaintiff immediately sent the Defendant
a Letter of Demand to cease using the premises for non-residential
purposes, which was received by the Defendant as shown in the letter
itself;
7) That on January 1, 2015, the Plaintiff sent the Defendant a Letter of
Demand to pay the unpaid rentals and to vacate the premises, which
was received by the Defendant as shown in the letter itself;
8) That the Defendant continues to occupy the leased premises up to the
present despite the repeated written and oral demands to vacate made
by the Plaintiff;
9)
III.
IV.
RESORT TO DISCOVERY
1)
Plaintiff does not intend to present any witnesses considering the summary
nature of the case.
RESPECTFULLY SUBMITTED.
Surigao City; 22 February 2015.