Escolar Documentos
Profissional Documentos
Cultura Documentos
II
ISSUES
I.
II.
III
STIPULATION OF FACTS
I.
II.
IV.
V.
VI.
IV
WITNESSES
BERTO C. CUERVO to testify that he
was with the accused on November 29,
2014 at 12 midnight.
YURI SINGZON as Operations
Manager to testify that, as, on the night
of November 29, 2014 at around 11:05
pm, John Lloyd E. Cruz personally
submitted to witness the Performance
Reviews of the seventeen (17) agents in
his team establishing the fact that
accused was not at the scene of the
crime the night Bradd Pitt was
murdered.
COL. RICHARD GUTIERREZ - will
testify as an expert witness to prove
that the deceased died of a fatal stab
wound
to
the
heart
disproving
prosecutions allegation of treachery.
DEFENSE RESERVES THE RIGHT TO
PRESENT ADDITIONAL DOCUMENTARY
AND TESTIMONIAL EVIDENCE IN THE
COURSE OF TRIAL.
VI
LAW/S APPLICABLE
REVISED PENAL CODE OF THE
PHILIPPINES
Art. 14. Aggravating circumstances
13. That the act be committed with
evident premeditation;
VIII
DEFENSE IS AMENABLE TO ENTER INTO
COMPROMISE SETTLEMENT UNDER
TERMS THAT ARE REASONABLE
IX
TRIAL DATES
DEFENSE SUBMITS TO THE CALENDAR
OF
CASES OF THIS HONORABLE COURT.
X
DEFENSE OBJECTS TO ANY
AMENDMENT
TO THE COMPLAINT AND/OR
INFORMATION
RESPECTFULLY SUBMITTED
Quezon City, January 30, 2015