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II.
III.
Description
Purpose
Original Certificate of
Title No. 0-5961 for
Green Paradise Island
in favor of PPAP
Contract of Sale
executed on December
1, 2015 between the
Plaintiff and Defendant
Corporation, as
represented by their
agents, the latter
conveying Paraiso
Island Resort to the
former
I-1
Photocopies of
Financial Statements of
Paraiso Island Resort
for the years 20102011
I-2
Photocopies of
Financial Statements of
Paraiso Island Resort
for the years 20112012
improvements on the
subject island resort prior
to the Sale and to reveal
the motivation of the
Plaintiff in procuring such,
i.e. the resorts economic
viability as shown by the
financial statements of
the Defendant
Corporation
I-3
Photocopies of
Financial Statements of
Paraiso Island Resort
for the years 20122013
Letters of Plaintiff
dated March 3, March
28, and April 17
demanding the delivery
of the improvements
Brochure of Paraiso
Island Resort
Webpage of Paraiso
Island Resort at
www.Paraiso.com
V. WITNESSES TO BE PRESENTED
The Plaintiff will present the following witness:
1. Liza Sobernako - To testify about the particular terms of the Contract
of Sale, the true intent of the parties in relation to the terms used in
said contract, and the ocular inspection conducted on the property
before the contract was executed.
2. Mocha Busog - To also testify about the terms of the Contract of Sale,
including the negotiations leading up to its execution, as the agent of
buyer Liza Sobernako. And to testify about the documents she
entered into directly and signed on behalf of the principal. This
witness will also authenticate the photographic evidence to be
presented.
VI. ISSUES
The Plaintiff proposes the following issues to be tried and
resolved by this Honorable Court:
1. Whether or not the defendant has an obligation to deliver the
remaining improvements embodied in the Contract of Sale.
2. Whether or not the defendant is liable for damages due to
non-delivery, in contravention of the tenor of its obligation under the
Contract of Sale.
VII.
Copy furnished:
Tongco & Cayosa Law Offices
Counsel for Defendant
Suite 1212, Herrera Tower,
V.A. Rufino cor. Valero Sts.,
Salcedo Village, Makati City