Pre-Trial Brief Sample
Pre-Trial Brief Sample
Pre-Trial Brief Sample
JULIE BARETA
Plaintiff Civil Case No. 463278
For: Damages arising
from Physical Injuries
- versus -
x-------------------------x
PRE-TRIAL BRIEF
Plaintiff JULIE BARETA, through the undersigned counsel, unto
this Honorable Court, most respectfully submits this Pre-Trial Brief:
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B. Theory of the Defendant
1.4. Defendant shifts the blame on plaintiff, holding that it was the
latter who caused her own injuries due to her own inattentiveness and
carelessness.
2.1. The jurisdiction of this Honorable Court over the subject matter
and over the person of the defendant;
2.3. The lack of proper lighting, warning signs, and barriers on July 8,
2019 when the incident happened;
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(e) ANNEX “E” – Invoice and official receipt issued by GAOC
Dental Clinic for dental implant surgery amounting to P80,000;
(f) ANNEX “F” – Return card showing proof of delivery of
plaintiff’s demand letter sent to defendant.
(g) Photos of plaintiff showing contusions and abrasions on her face
and leg;
(h) X-ray of plaintiff’s left ankle;
(i) Dental x-ray of plaintiff showing traumatic dental injury on her
lower left molar; and
(j) Photos of the excavated road taken a day after the incident.
V. ISSUES
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VI. EVIDENCE FOR THE PLAINTIFF
A. Testimonial Evidence
B. Documentary Evidence
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1. ANNEX “A” – Official receipt issued by Loyola Grand Villas Clinic
for the use of the ambulance van amounting to P2,500;
C. Object Evidence
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RESPECTFULLY SUBMITTED.
EXPLANATION