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Motion For Postponement

This document is a motion for postponement filed in the Regional Trial Court of Panabo City, Philippines. [1] The defendants' lawyer is requesting to postpone a hearing scheduled for August 7, 2012 regarding a civil case between the Municipality of Carmen and Wilfredo Botenes et al. [2] The reason for the request is that the defendants' representative, Lilia Botenes, has a previously scheduled office planning conference in Cebu and Bohol on that date and wishes to attend all hearings. [3] The lawyer is asking the court to reschedule the hearing to the earliest possible date.

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Galgs Borge
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348 views2 pages

Motion For Postponement

This document is a motion for postponement filed in the Regional Trial Court of Panabo City, Philippines. [1] The defendants' lawyer is requesting to postpone a hearing scheduled for August 7, 2012 regarding a civil case between the Municipality of Carmen and Wilfredo Botenes et al. [2] The reason for the request is that the defendants' representative, Lilia Botenes, has a previously scheduled office planning conference in Cebu and Bohol on that date and wishes to attend all hearings. [3] The lawyer is asking the court to reschedule the hearing to the earliest possible date.

Uploaded by

Galgs Borge
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOC, PDF, TXT or read online on Scribd

Republic of the Philippines

REGIONAL TRIAL COURT


11th Judicial Region
BRANCH 4,
Panabo City

MUNICIPALITY OF CARMEN, ET. AL CIVIL CASE NO. 97-29


Plaintiff,
REFORMATION OF
- versus - INSTRUMENT

WILFREDO BOTENES, ET. AL.,


Defendants.
x------------------x

MOTION FOR POSTPONEMENT

Defendants, through counsel and unto this Honorable Court,


most respectfully submits this motion by averring that:

1. This case was set for hearing on August 7, 2012 at 8:30 in


the morning for initial presentation of the evidence for the plaintiffs.

2. However, the representative of the defendants, Lilia C.


Botenes, has to attend to a previously scheduled office internal
planning conference in Cebu and Bohol. She expressed her desire to
attend every hearing of this case so that she could have something
to report to her siblings personally. In view thereof, the undersigned
counsel is constrained to ask for a resetting of this case at the
earliest possible time. This motion is filed in good faith and not
intended to delay the proceedings of this case.

WHEREFORE, it is most respectfully prayed that this motion be


granted and that this case be reset to such date as may be
determined by the court.

RESPECTFULLY SUBMITTED this July 30, 2012, Tagum City (for


Panabo City), Davao del Norte, Philippines.

GALGO RACHO & WAKAN LAW FIRM


2nd Floor CTC Business Center
Rizal Street, Tagum City, Davao del Norte
Email Add.: grw_lawfirm@[Link] Telephone No. 216-4471
Smart: 09394539711 Globe: 09173468177 Sun: 09238477211

By:
ATTY. NUMERIANO P. GALGO, JR.
Counsel for Defendants
PTR No. 1165545; 01-02-2012, Tagum City
IBP O.R. No. 851361; 12-27-2011 (for 2012) Tagum City
Roll No. 53267; TIN 266-299-414
MCLE Compliance No. III-0005222; Pasig City
MCLE Compliance No. IV-0000845; Pasig City

Copy furnished:

ATTY. Jennifer B. Namoc/Atty. Edd Mark O. Wakan


Counsel for Municipality of Carmen Rec. No. ________
Capitol Bldg., Mankilam, Tagum City Date:___________

ATTY. MADISON GABAYAN Reg. Rec. No. ____


Counsel for One Network Bank Date:___________
JFM Corporation Center, 848 Atis St.,
Juna Subdivison, 8021 Matina, Davao City

NOTICE OF HEARING

Greetings!

Please take notice that the foregoing motion is set for hearing on
August 7, 2012 at 8:30 in the morning sans at presence of
undersigned counsel.

ATTY. NUMERIANO P. GALGO, JR.

Explanation of service by registered mail: A copy of this motion was


filed and served by registered mail due to distance constraints.

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