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REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
MANILA CITY, BRANCH____

FERDINAND M. JOSE
Plaintiff,
-versus-

CIVIL CASE NO._____

FOR: DAMAGES

HAYDEN C. MANUEL
Defendant.
x---------------------------------x

DEFENDANTS PRE-TRIAL BRIEF

Defendant, through undersigned counsel, respectfully submits

this Pre-Trial Brief unto before this Honorable Court, in compliance
with the trial courts order.

Amicable Settlement

Respondent is willing to enter into an amicable settlement of

the case, under term and condition agreeable to both parties and
submit to alternative modes of dispute resolution.

BRIEF STATEMENT OF THE CASE

This case is for an action for damages filed by the plaintiff in

the above mentioned case. That plaintiff is allegedly entitled thereto,
because of the medical malpractice of the defendant in his

performance in the operation made by the latter against the

plaintiff.

ADMITTED FACTS

1. That he is the defendant of the above-mentioned case:

2. That the defendant ADMITS the allegations of the plaintiff in

paragraphs 2, 3, 4, 5, 7, 10 and 13 of the complaint;

Proposed Stipulation of Facts

Defendant requests that plaintiff admits the following facts:

1. That the(ano ung gusto mong ma admit on the part of the

plaintiff here)

Issues

1. Whether or not the prayer for moral and exemplary damages and
attorneys fees should be granted;

2. Whether or not the plaintiff has a cause of action to file the

complaint.

List of Witnesses
1. Defendant himself to testify on the material allegation
2. lahat ng witnesses na gusto mong malagay example witness 1to corrobate the testimony na siya as nurse ay nag perform nung
operation kasama ni doc.. etc

Reservation

Plaintiff 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.

Makati City for the City of Manila, November 11, 2015

BD-MVPS LAW FIRM

Counsel for Defendants
th
5 Floor GC Corporate Tower
Legaspi, San Lorenzo Village
Makati City

By:

Floyd Mago
PTR NO. 1245678; SFC: 2/10/07
IBP O.R. No. 745392; Manila; 03/73/07
Attorneys Roll No. 84729

COPY FURNISHED by Personal Service:

JOSE MARIA MARQUEZ
Counsel for the Plaintif
Unit 2808, Palm Towers,
San Antonio Village, Makati City
Tel. 333-9999