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Republic of the Philippines

REGIONAL TRIAL COURT


Third Judicial Region
Branch 66
Capas, Tarlac

IN RE: PETITION FOR THE CORRECTION OF


ENTRIES IN THE CIVIL REGISTER OF
CAPAS, TARLAC PERTAINING TO
THE RECORD OF BIRTH OF
CRISTINE CAPULONG,
CRISTINE A. CAPULONG,
P e t i t i o n e r,
SPEC. PROC. NO. 374
THE LOCAL CIVIL REGISTRAR OF
CAPAS, TARLAC,
R e s p o n d e n t.
x--------------------------------------------------x

EX PARTE MOTION TO CONDUCT


ADVANCE TESTIMONY BY
DEPOSITION
PETITIONER through the undersigned counsel and before this Honorable
Court, respectfully states:

1. That pursuant to the Order of the Honorable Court dated April 24, 2006,
the above-entitled case is set for initial hearing on 30 June 2006 at 8:30
in the morning, copy of which Order having been published in a
newspaper of general circulation in the province of Tarlac on April 28,
May 5 and 12, 2006 as shown by a copy of the Publishers Affidavit
attached hereto as Annex A;

2. That on 30 May 2006, the Office of the Solicitor General has filed its
Entry of Appearance before this Honorable Court, therein authorizing the
Public Prosecutor to appear in its behalf in this case;

3. That in the meantime, the petitioner is bound to leave for abroad


before the 15th day of this month;

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4. That so as to take advantage of the remaining limited stay of the
petitioner in the country as her return to the Philippines may take a
longer time, it is practical if not equitable to allow the petitioner to
give her advance testimony by way of oral deposition so that the
proceedings in this case will not be unnecessarily delayed with the
indefinite return of the petitioner.

WHEREFORE, premises considered, it is most respectfully prayed that the


petitioner be allowed to give her advance testimony by way of an oral deposition
preferably on June 12, 2006 subject to the convenience and availability of the
calendar of this Honorable Court.

OTHER RELIEFS AND REMEDIES which are just and equitable in the
premises are likewise prayed for.

Capas, Tarlac, 01 June 2006.

ROSELLER B. RODRIGUEZ
Counsel for the Petitioner
Sto. Domingo II, Capas 2315 Tarlac
PTR No. 0835745/01-02-06/Capas, Tarlac
IBP No. 594069/01-02-06/ Tarlac Chapter
Roll No. 41013; Book 17; Page 203

The CLERK OF COURT


RTC - Branch 66
Capas, Tarlac
Greetings:
Upon receipt hereof, kindly submit the foregoing ex-parte motion for the
consideration and approval of the Honorable Court.

ROSELLER B. RODRIGUEZ

Copy Furnished:

Office of the Local Civil Registrar


Municipal Hall
Capas, Tarlac
Hon. Lorenzo B. Parairo
Office of the Provincial Prosecutor
Tarlac City