VII

DISCOVERY PROCEDURES

Considering the relatively simple issues presented, the 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 discovery
before trial.

VIII
NAMES OF WITNESSES
AND THE SUBSTANCE OF THEIR TESTIMONIES

The Plaintiff will present the following three (3) witnesses:

1. Plaintiff himself, who shall testify on the material allegations,

causes of action and the claims set forth in the Complaint;

2. Pedro Juan, the who shall testify to establish the authenticity of

the signature of the defendant in EXHIBIT 1 and the receipt of
the copies thereof;

3. Maria Makiling, the owner of Coffee-Choco Restaurant, offered

to prove the due execution and of EXHIBIT 1 and the
authenticity thereof;

Plaintiff reserves the right to present additional witnesses during

the course of the trial upon showing good cause and in the interest
of substantial justice.

IX
APPLICABLE LAWS AND JURISPRUDENCE

The Plaintiff grounds its claims on the following laws and

jurisprudence:

1. Applicable Provisions of the Civil Code of the Philippines

particularly on the Laws on Obligations and Contracts and Laws
on Loans;

2. Applicable Provisions of the Commercial Laws of the Philippines;

3. Applicable Decision of the Supreme Court.

1
 X
CALENDAR DATE FOR TRIAL
The Plaintiff respectfully informs this Honorable Court of
his willingness to proceed to an actual trial of the case whenever
necessary at the convenient time to the parties and the calendar of
this tribunal.
WHEREFORE, premises considered, it is respectfully
prayed unto this Honorable Court that the foregoing Pre-Trial Brief
be duly noted.

Respectfully submitted.
Malolos City,, Bulacan for City of Manila, 17 October 2017.

By:

LLB WORKING CLASS LAW OFFICES

#051 Lopez Street, Mojon, Malolos City, Bulacan
Email Address: llbworkingclass@yahoo.com

By:

ATTY ACDE XYZ

Counsel for the Complainant
Roll of Attorney No. 54236
PTR NO. 25643, Malolos City, January 10, 2017
IBP NO. 24358, Malolos City, January 4, 2017
MCLE Compliance No. V-000698

Copy furnished:

SALUDO & ASSOCIATES

Counsels for the Defendants