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PRE-TRIAL BRIEF
1.1 Petitioner pleads the court to declare the nullity of his marriage with the respondent due to
psychological incapacity.
2.1. Petitioner admits that both him and respondent underwent psychological evaluation under the
same psychologist.
3.1.2. The unawareness of respondent that she is under psychological evaluation affects the
findings of the psychologist
IV. EVIDENCE/WITNESSES:
4.1.1 Dr. Jean Paul Gueco to establish the psychological incapacity of the wife present prior to the
celebration of the marriage.
4.1.2. Plaintiff reserves the right to present any and all documentary evidence, which shall become
relevant to rebut respondents claims in the course of trial as well as any other witnesses whose
testimony will become relevant to
belie defendants witnesses, if necessary.