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    Pre Trial Brief

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    bhem silverio
    This document is a pre-trial brief submitted by the defense counsel for four accused - Bryan Zafra, Aiken Lopez, Ryan Café, and Alberto Manalang - who have been charged with kidnapping for ransom. The brief admits that the incident was reported on November 6, 2012 and the accused were arrested on February 15, 2013. It reserves the right to present documentary and testimonial evidence during trial. The issues to be tried are whether the accused were present during the crime and whether they are guilty given the required evidence and elements of kidnapping for ransom. The defense requests three trial days.

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    © All Rights Reserved
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    Pre Trial Brief

    Uploaded by

    bhem silverio
    341 views4 pages
    This document is a pre-trial brief submitted by the defense counsel for four accused - Bryan Zafra, Aiken Lopez, Ryan Café, and Alberto Manalang - who have been charged with kidnapping for ransom. The brief admits that the incident was reported on November 6, 2012 and the accused were arrested on February 15, 2013. It reserves the right to present documentary and testimonial evidence during trial. The issues to be tried are whether the accused were present during the crime and whether they are guilty given the required evidence and elements of kidnapping for ransom. The defense requests three trial days.

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    Sample Pre-Trial Brief for law students

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    This document is a pre-trial brief submitted by the defense counsel for four accused - Bryan Zafra, Aiken Lopez, Ryan Café, and Alberto Manalang - who have been charged with kidnapping for ransom. The brief admits that the incident was reported on November 6, 2012 and the accused were arrested on February 15, 2013. It reserves the right to present documentary and testimonial evidence during trial. The issues to be tried are whether the accused were present during the crime and whether they are guilty given the required evidence and elements of kidnapping for ransom. The defense requests three trial days.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    341 views4 pages

    Pre Trial Brief

    Uploaded by

    bhem silverio
    This document is a pre-trial brief submitted by the defense counsel for four accused - Bryan Zafra, Aiken Lopez, Ryan Café, and Alberto Manalang - who have been charged with kidnapping for ransom. The brief admits that the incident was reported on November 6, 2012 and the accused were arrested on February 15, 2013. It reserves the right to present documentary and testimonial evidence during trial. The issues to be tried are whether the accused were present during the crime and whether they are guilty given the required evidence and elements of kidnapping for ransom. The defense requests three trial days.

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    © All Rights Reserved
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    You are on page 1of 4

    Republic of the Philippines

    NATIONAL CAPITAL JUDICIAL REGION


    REGIONAL TRIAL COURT
    Pasay City, Branch 53

    PEOPLE OF THE PHILIPPINES,


    Plaintiff,

    - Versus - CRIM. CASE NO. 5409


    For: Kidnapping for Ransom

    BRYAN ZAFRA
    AIKEN LOPEZ
    RYAN CAF
    ALBERTO MANALANG
    Accused.

    x-------------------------------------------x

    PRE-TRIAL BRIEF
    OF THE ACCUSED

    THE ACCUSED, by counsel, respectfully submits the following Pre-trial Brief:

    SUMMARY OF ADMITTED FACTS


    The following are the admitted facts:

    1. The incident was reported to the police on November 6, 2012;

    2. The accused were arrested on February 15, 2013;


    DOCUMENTARY EXHIBITS

    EXHIBITS DESCRIPTION
    1

    The accused reserves the right to present additional documentary evidence during the pre-
    trial.

    TESTIMONIAL EVIDENCE
    The accused intends to present the following witnesses:

    (a) The accused persons shall testify on the material averments contained in their
    counter-affidavit;

    (b) Julian Roman Reyes shall testify on his affidavit and the truth of the matters
    contained therein;

    (c) Erwin B. Belen shall testify on his affidavit and the truth of the matters
    contained therein;

    (d) Rupert Aaron Villarico shall testify on his affidavit and the truth of the matters
    contained therein;

    (e) Ma. Brimar Makasiar shall testify on his affidavit and the truth of the matters
    contained therein;

    The accused reserves the right to present additional documentary evidence during the pre-
    trial and trial.
    ISSUES TO BE TRIED
    The accused submits the following issues for the resolution of this Honorable Court:

    I. Whether the accused persons were actually and physically present at the time and
    place when the crime of kidnapping for ransom was committed as to warrant
    conviction of the same;

    II. Whether the accused is guilty in accordance of the quantum of evidence required and
    the elements of the crime of kidnapping for ransom.

    TRIAL DATES
    We respectfully request for at least 3 trial days, with the regular appearance of the
    undersigned City Prosecutor before this Honorable Court.

    Respectfully submitted.

    Makati City for Pasay City, Philippines, August 17, 2013.

    SILVERIO LAW OFFICES

    Counsel for the Accused

    5th Floor, Makati Executive Tower III

    167, Gil Puyat Avenue, Makati City

    BY:
    ATTY. MELVIE E. SILVERIO
    Roll of Attorney No. 51486

    PTR No. 0987256, Jan. 4, 2009, Pasay

    Series No. of Commission 0854481

    IBP No. 729988

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