REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT

__________________________
______________________

___________________,
Plaintiff,

- versus - CIVIL CASE NO. ______

____________________,
Defendants
X-------------------------X

PRE-TRIAL BRIEF FOR THE PLAINTIFF

Plaintiff, through the undersigned counsel, and unto this Honorable

Court most respectfully submits the following pre-trial brief, to wit:

I. STATEMENT OF CLAIMS OF THE PLAINTIFF;

1. The plaintiff lend the sum of THIRTY THOSAND (Php30,

000.00) PESOS to the defendant because the defendant pleaded
that if the plaintiff will lend her such amount the defendant will
pay it on a hire basis. The defendant will hire the money in the
amount of ONE HUNDRED PESOS per day for TEN THOUSAND
PESOS;

2. The defendant requested the plaintiff to hire the sum of THIRTY

THOUSAND PESOS (Php30,000.00) for ten days;

3. The hiring rate is ONE HUNDRED PESOS per day for every TEN
THOUSAND PESOS;

4. Another TEN THOUSAND PESOS (Php10, 000.00) was

borrowed by the defendant sometime in January and February.
In fact the plaintiff should give such money to a certain
______________ being a member of their PALUAGAN group.
However, the defendant requested ___________ that the said
amount be lend first to her. Defendant was not able to pay the
said amount and told to ___________ that the plaintiff will be the
one to pay and she will hire the money for ONE HUNDRED
PESOS per day for every TEN THOUSAND PESOS (Php10,
000.00);

The plaintiff is claiming only TEN PERCENT (10%) interest per

month from May 2005 up to the present;

II. AMICALBLE SETTLEMENT AND ALTERNATIVE MODE OF DISPUTE

RESOLSUTION
 Plaintiff is willing to enter into an amicable settlement of dispute
under fair and equitable conditions;

III. ISSUES

Whether or not plaintiff has course of action against the defendant

to claim EIGHTY EIGHT THOUSAND (Php88, 000.00) from the
defendant.

IV. APPLICABLE LAWS

Civil Code of the Philippines;

V. WITNESSES TO BE PRESENTED

Two (2) witnesses including the plaintiff;

VI. RESERVATION TO PRESENT OTHER WITNESSES AND

DOCUMENTARY EVIDENCE

The plaintiff reserves the presentation of other witnesses in the

course of the trial of the case.

VII. AVAILABLE TRIAL DATES

Every Wednesday afternoon.

Respectfully submitted.

___________________________
___________________________

Copy furnished:

____________________
____________________
____________________