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Pre Trial Brief of The Accused

This document is a pre-trial brief submitted by the defense counsel for accused Vergel "Agong" Katakutan and Xander "Boy epal" Ruiz, who have been charged with kidnapping. It proposes that the accused do not admit all the allegations in the information filed against them. It also lists documentary evidence in the form of counter-affidavits from each accused, and testimonial evidence from each accused to controvert the allegations. The brief is respectfully submitted to the court by defense counsel Atty. Kho Boombastic for consideration.

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Angelica Joyce Visaya Ignacio
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238 views2 pages

Pre Trial Brief of The Accused

This document is a pre-trial brief submitted by the defense counsel for accused Vergel "Agong" Katakutan and Xander "Boy epal" Ruiz, who have been charged with kidnapping. It proposes that the accused do not admit all the allegations in the information filed against them. It also lists documentary evidence in the form of counter-affidavits from each accused, and testimonial evidence from each accused to controvert the allegations. The brief is respectfully submitted to the court by defense counsel Atty. Kho Boombastic for consideration.

Uploaded by

Angelica Joyce Visaya Ignacio
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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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


FIRST JUDICIAL REGION
BRANCH 15, LAOAG CITY
PEOPLE OF THE PHILIPPINES,
Plaintiff,
CRIMINAL CASE NO. 069-15
-versusFor:
VERGEL Agong KATAKUTAN and
XANDER Boy epal RUIZ,

Kidnapping

Accused.
x---------------------------------------------x

PRE TRIAL BRIEF


COMES NOW the accused, through the undersigned counsel, and
unto this Honorable Court, most respectfully submits their Pre-Trial Brief, to
wit:
PROPOSED STIPULATIONS OF FACTS
1. The accused do not admit all the allegations in the information
filed against them.

DOCUMENTARY EVIDENCE
1. Exhibit 1 The Counter-Affidavit of VERGEL Agong
KATAKUTAN
2. Exhibit 2 The Counter-Affidavit of XANDER Boy epal RUIZ.

TESTIMONIAL EVIDENCE
1. Accused VERGEL Agong KATAKUTAN to testify to

controvert the allegations against him; and


2. Accused XANDER Boy epal RUIZ to testify to controvert
the allegations against him.

RESPECTFULY SUBMITTED.
Laoag City, Philippines. April 20, 2015.

ATTY. KHO BOOMBASTIC


(Counsel for the Accused)
Roll No. 96682
IBP No. 312444 - I. N. L. C. 12/07/14 (for CY 2015)
PTR No. 13225 - I. N. L. C. 01/07/15
MCLE Compliance No. IV 134521- 12/05/2013
Address: Brgy. 2, Galgalapok, Laoag City
Tel No. 897-4315

NOTICE
The Clerk of Court
RTC-Branch 14
Laoag City
GREETINGS!
Please submit the foregoing Pre-Trial Brief for the kind consideration
and approval of the Most Honorable Court.

KHO BOOMBASTIC

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