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  • Pre-Trial Brief: Shiena Marie Consing

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    Argie E. NACIONAL
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    1. This document is a pre-trial brief submitted by the defendant Jaymart Dusog in the civil case filed against him by Shiena Marie Consing for the sum of money. 2. The defendant admits that he received a loan of P250,000 from the plaintiff but invested the money in a "Double your Money Scam" and became insolvent. 3. The defendant proposes that the facts stipulated include that there was no specific repayment date agreed upon and that he responded to explain his inability to pay in response to the demand letters from the plaintiff.

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    Pre Trial Brief

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    1. This document is a pre-trial brief submitted by the defendant Jaymart Dusog in the civil case filed against him by Shiena Marie Consing for the sum of money. 2. The defendant admits that he received a loan of P250,000 from the plaintiff but invested the money in a "Double your Money Scam" and became insolvent. 3. The defendant proposes that the facts stipulated include that there was no specific repayment date agreed upon and that he responded to explain his inability to pay in response to the demand letters from the plaintiff.

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    43 views3 pages

    Pre-Trial Brief: Shiena Marie Consing

    Uploaded by

    Argie E. NACIONAL
    1. This document is a pre-trial brief submitted by the defendant Jaymart Dusog in the civil case filed against him by Shiena Marie Consing for the sum of money. 2. The defendant admits that he received a loan of P250,000 from the plaintiff but invested the money in a "Double your Money Scam" and became insolvent. 3. The defendant proposes that the facts stipulated include that there was no specific repayment date agreed upon and that he responded to explain his inability to pay in response to the demand letters from the plaintiff.

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    © All Rights Reserved
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    of 3

    Republic of the Philippines

    REGIONAL TRIAL COURT


    Branch 19, Iloilo City

    Shiena Marie Consing,


    Plaintiff,

    -versus- Civil Case No. 008795


    For: Sum of Money

    Jaymart Dusog,
    Defendant,
    x----------------------------------------------------------------------------------------x

    PRE-TRIAL BRIEF
    (FOR THE DEFENDANT)

    DEFENDANT, by himself, and unto this Honorable Court, most


    respectfully submits this Pre-Trial Brief, to wit:

    I. POSSIBILITY OF AMICABLE SETTLEMENT

    The DEFENDANT manifests that he is willing to explore


    possibilities for an amicable settlement that is fair and reasonable
    under the circumstances.

    II. SUMMARY OF ADMITTED AND PROPOSED STIPULATION


    OF FACTS

    A. SUMMARY OF ADMITTED FACTS

    Defendants admits the following facts, to with:

    1. The Defendant admits that he got a loan from the


    plaintiff with the amount of Two Hundred Fifty Thousand
    Pesos (P250,000.00);

    2. The Defendant admits that demand letters were indeed


    sent to him and that he sent replies explaining that he
    became insolvent after investing his money to “Double
    your Money Scam”;
    III. SUMMARY OF PROPOSED STIPULATION OF FACTS

    Defendant proposes the following facts to be admitted by the


    Plaintiff, to wit: -THAT-

    1. There was no specific date agreed by the parties to pay


    said amount.

    2. That after giving out demand of payment to the defendant,


    the defendant therein answered explaining as to why he
    still hasn’t paid.

    IV. STATEMENT OF THE ISSUES

    A. Whether or not the Defendant has purposely evaded


    payment of his loan.

    B. Whether or not the demand of payment from the defendant


    is legal when he already made known of his insolvency.

    C. Whether or not Defendant is entitled to DAMAGES.

    V. APPLICABLE LAWS AND JURISPRUDENCE

    1. Applicable jurisprudence issued by the Supreme Court.

    2. Pertinent provisions of the New Civil Code applicable.

    3. Revised Rules on Summary Procedures applicable.

    VI. DOCUMENTARY EVIDENCE

    Defendant shall present the following documentary pieces of


    evidence:

    1. Original copy of the Demand Letters from the Plaintiff.

    2. Original copy of the Response of the Defendant.

    Defendant reserves his rights to present additional documentary


    evidence during the proceedings upon permission of this Honorable Court.
    VII. MODES OF DISCOVERY PROCEDURE

    Defendant intends to avail of discovery procedures or referral to


    commissioners when necessary.

    PRAYER

    WHEREFORE, premises considered, it is most respectfully


    prayed of this Honorable Court that the PRE-TRIAL BRIEF be NOTED.

    Other reliefs just and equitable under the foregoing are likewise
    being prayed for.

    Respectfully submitted.

    City of Iloilo, May 2021.

    ( Sgd. ) Jannessah Guillano


    Counsel for Defendant
    Jaro ,Iloilo City
    Roll No. 42195
    IBP No. 67, Iloilo City, 8-2-20
    PTR No. 444 , Iloilo City, 7-2-20
    MCLE Compliance No. 8483, 6-2-10

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