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Pre-Trial Script

1) The case of Vladimir Putin Serafin v. Kim Jun Longcop for recovery of possession is called before Judge Sixto Estudillo. Attorneys for both the plaintiff and defendant indicate they are ready for pre-trial. 2) The judge asks the parties if there is a possibility of an amicable settlement or submission of a compromise agreement. 3) The attorneys for each party are asked to state their theory of the case and proposed stipulations of fact. They discuss admitting or denying certain proposed stipulations. 4) The judge asks the plaintiff's attorney to present the factual issues in their case and provide supporting evidence.

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Victor Sarmiento
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6K views3 pages

Pre-Trial Script

1) The case of Vladimir Putin Serafin v. Kim Jun Longcop for recovery of possession is called before Judge Sixto Estudillo. Attorneys for both the plaintiff and defendant indicate they are ready for pre-trial. 2) The judge asks the parties if there is a possibility of an amicable settlement or submission of a compromise agreement. 3) The attorneys for each party are asked to state their theory of the case and proposed stipulations of fact. They discuss admitting or denying certain proposed stipulations. 4) The judge asks the plaintiff's attorney to present the factual issues in their case and provide supporting evidence.

Uploaded by

Victor Sarmiento
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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SCRIPT:

Barker: All rise, the Honorable Sixto Estudillo presiding. [The judge bangs the gavel
thrice.]

J. Estudillo: Call the cases.

Clerk of Court: No. 1 in the calendar your Honor is the case of Vladimir Putin
Serafin v. Kim Jun Longcop for Recovery of Possession:

J. Estudillo: Counsel for PLaintiff

Atty. Victor: For the plaintiff, your Honor, ready for Pre-Trial.

J. Estudillo: Counsel for defendant

Atty. Whoever: For the defendant, your Honor, ready.

The court notes that both parties had submitted their respective pre-trial briefs

The court then asks for the possibility of amicable settlement, submission of compromise
agreement

Insert script for amicable settlement

J. Estudillo: Atty Victor, may you state your theory of the partys claim?

Atty. Victor recites the theory

J. Estudillo: Atty Melvic, please state your theory of the defendants case.

Atty. Melvic recites theory

J. Estudillo: Atty. Victor, please state your request for stipulations.

Atty. Victor recites proposed admissions/stipulations of facts

(In this instance, we shall decide what facts must be admitted as part of the play,
including conditions precedent, prior repeated demand, jurisdictional facts, etc.)

Example:

Atty. Victor: Your Honor, as stated in our pre-trial brief, we request the following stipulations:

1) That the property in question is registered under the plaintiffs name as


appearing in TCT No. ____________.
Atty. Melvic: We cannot stipulate on that, your Honor.

Atty. Victor: 2) That a demand letter was sent and received by the Defendant on ___________
as shown in a copy of that demand letter with proof of receipt via registered mail attached to the
demand letter.

Atty. Melvic: Admitted, your Honor.

Atty. Victor: 3) That despite receipt of that demand letter the defendant refused to vacate the
property in issue.

Atty. Melvic: Admitted, your Honor.

Atty. Victor: That will be all for the plaintiff, your Honor.

J. Estudillo: Alright, Atty. Melvic, any proposed stipulations?

Atty. Melvic: Yes, your Honor.

1) That the property has not been offered for sale to the defendant who has the
right of first refusal.

Atty. Victor: Denied, your Honor.

Atty. Melvic; 2) That the defendant is able and willing to purchase the property in question at a
reasonable price.

Atty. Victor: We cannot stipulate on that, your Honor.

Atty. Melvic: That will be all for the defendant, your Honor.

Factual issues asked by Judge

Atty Victor: Your honor, as stated in our pre-trial brief, here are my factual issues:

Atty Victor recites the factual issues and provides evidence to support

J. Estudillo: Alright, please pick your available dates for the marking of your respective
documentary exhibits before the Branch Clerk of Court.

Atty. Victor: May we have October 20, 2017 at 1:30 p.m., your Honor.

Atty. Whoever: Available, your Honor.


Examples:

- On marking of evidence.

J. Estudillo: Atty. Victor, do you tend to adopt the evidence as part of your case?

Atty. Victor: Yes your honor we adopt the evidence as part of our case and request
that it be marked as exhibit 5 for the plaintiff.

- On admission of facts:

Atty Victor: Your honor we admit and stipulate that the Foreshore lease was duly issued
and executed in accordance with law and that it is genuine.

Judge E: Atty. Melvic do you submit to the due execution and genuineness of the
foreshore lease agreement?

Atty Melvic: Yes your honor, we submit to the genuineness and due execution but not
to the contents of said document.

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