Republic of the Philippines MUNICIPAL TRIAL COURT IN CITIES First Judicial Region Branch 7, Bacolod City

THE PEOPLE OF THE PHILIPPINES, Plaintiff, - versus Criminal Case No. 6650 Concubinage

ALFREDO BUSUEGO, EMILY SIA AND JULIE DE LEON Accused, x--------------------x DEFENDANTS PRE-TRIAL BRIEF
DEFENDANT, by counsel and unto the Honorable Court, most respectfully submits this Pre-Trial Brief:

Willingness to Enter into Amicable Settlement

Defendant is open and willing to enter into an amicable settlement or compromise under the following terms: 1. __________________________ 2. __________________________ 3. __________________________

Alternative Modes of Dispute Resolution

Defendant is willing to submit itself to mediation and other alternative modes of dispute resolution.

Brief Statement of Defense

Defendant, in its Answer with Counterclaims, dated _____________, prays for the dismissal of the complaint on the ground that _____________.

Admitted Facts
Defendant admits the following facts: 1. __________________________ 2. __________________________ 3. __________________________

Defendant is open to stipulations over and above the foregoing admissions.

Proposed Stipulation of Facts

Defendant requests Plaintiff to admit the following facts: 1. __________________________ 2. __________________________ 3. __________________________

Issues

Defendant respectfully submits that the issues in this case are:

1. Whether or not __________________________

2. Whether or not __________________________ 3. Whether or not __________________________

List of Exhibits to be presented

Defendant will present the following exhibits:

1. ____________________ - to prove that _____State the Purpose_____ 2. ____________________ - to prove that _____State the Purpose_____ 3. ____________________ - to prove that _____State the Purpose_____

Witnesses to be presented

Defendant will present the following witnesses:

1. Defendant (himself/herself) - to testify on the materials allegations, affirmative allegations, and special and affirmative defenses and the denials in (his/her) Answer and Counterclaims and to testify on the damages caused to (him/her) by the filing of this action;

2. _____________ - to corroborate the testimony of the Defendant on its material points and to testify that __________________________;

3. _____________ - to corroborate the testimony of the Defendant on its material points and to testify that __________________________;

Defendant will need at least ___________ (______) (hour/minutes) per witness, exclusive of cross-examination, rebuttal and sur-rebuttal evidence.

Reservation

Defendant expressly reserves the right to present such additional witnesses and other exhibits and evidence as the exigencies of the trial may require.

Specific Trial Dates

It is respectfully requested that the trial dates be set during the pre-trial conference to dates most convenient to this Honorable Court and to all the parties.

MOST RESPECTFULLY SUBMITTED.

_____________, Philippines, __Date__.

(COUNSEL)

COPY FURNISHED:

OPPOSING COUNSEL

(EXPLANATION)