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EX PARTE MOTION TO SET CASE FOR PRE-TRIAL

Plaintiff, by undersigned counsel and unto this


Honorable Court, respectfully states:

1. On _____________, undersigned received a copy of


defendant's Answer in this case;

2. Considering that a Reply to the said Answer is no


longer necessary due to the fact that said Answer
does not raise any new or substantial issue, or raise
issues which should more properly be addressed during
the trial proper, the said Answer is therefore the
last pleading contemplated by the Rules of Court;

3. As such, undersigned respectfully requests that


the instant case be immediately set for pre-trial.

WHEREFORE, it is respectfully prayed that the instant


case be immediately set for pre-trial, pursuant to
Rule 18 of the Rules of Court.

Other relief just and equitable are likewise prayed


for.

_____________, Philippines, __Date__.

(COUNSEL)

(NOTICE OF HEARING)

(EXPLANATION)

COPY FURNISHED:

OPPOSING COUNSEL

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