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XI MOTIONS
H. PRE-TRIAL
Form No. 1--Motion
to Set Case for Pre Trial
(Motion
to Set Case for Pre Trial)
(CAPTION)
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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