Pre-Trial Guide: COMES NOW, ACCUSED, Assisted by The - , by The Undersigned Counsel

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Republic of the Philippines

REGIONAL TRIAL COURT


11th Judicial Region
Branch

PEOPLE OF THE PHILIPPINES Criminal Case No.


Plaintiff,

-versus- FOR: VIOL. Of Sec. 5 and Sec. 11,


ART. II of R.A 9165 KNOWN AS THE
COMPREHENSIVEDANGEROUS
Accused. DRUGS ACT.
x-----------------------------------------x

PRE-TRIAL GUIDE

COMES NOW, ACCUSED, assisted by the -, by the undersigned counsel


and unto this Honorable Court, respectfully submit this Pre-Trial Guide and
herein propose the following stipulations, THAT:

1. The investigating officer has NO personal knowledge of the buy-bust


operation conducted with the regard to this case;

2. The receiving officer and the forensic chemical officer of the Davao del
Norte Police Provincial Crime Laboratory have NO personal knowledge
on how the accused was arrested;

3. The receiving officer and the forensic chemical officer of the Davao del
Norte Police Provincial Crime Laboratory have NO personal knowledge
on how and where the specimen/s was/were marked by the arresting
and seizing officer;

4. The receiving officer and the forensic chemical officer of the Davao del
Norte Police Provincial Crime Laboratory have NO personal knowledge
on who took the custody of the specimen/s from the place of arrest and
/or seizure to the office of the team that conducted the drug operation;

5. The receiving officer and the forensic chemical officer of the Davao del
Norte Police Provincial Crime Laboratory have NO personal knowledge
on how the specimen/s was/were transported from the place of arrest
or seizure to the office of the team that conducted the drug operation;

6. The receiving officer and the forensic chemical officer of the Davao del
Norte Police Provincial Crime Laboratory have NO personal knowledge
on how the specimen/s was/were kept at the office of the team that
conducted the drug operation.

7. As to the witness of the defense, we will be presenting the following:

a. The Accused himself,


b. Reservation to present additional witness during the course of
the trial.

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8. With respect to the documentary evidence, with reservation in the
course of the proceedings.

WHEREFORE, premises considered, it is respectfully prayed of this


Honorable Court that the proposed stipulations be duly noted in the records
of the case.

RESPECTFULLY SUBMITTED., Philippines. February 15, 2019.

By:

Copy furnished:

Office of the City Prosecutor

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