REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
BACOLOD CITY
BRANCH 14

Otto Potato
Plaintiff,

- versus - Civil Case No. 15-666

For: REPLEVIN

Jane Doe and

John Doe,
Defendants.
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MOTION FOR POSTPONEMENT OF HEARING

Plaintiff, through counsel and unto this Honorable Court,

respectfully states that:

1. The Pre-trial of this case was set on August 27, 2019.

Due to defendant’s failure to appear on the said pre-trial, this
Honorable Court ordered the ex parte presentation of plaintiff’s
evidence, to be held on September 24, 2019at 8:30 in the morning.

2. Defendant’s counsel filed a Motion for Reconsideration

and the same was heard on September 11, 2019. The undersigned
counsel was ordered by this Honorable Court to make an oral
comment and opposition to the said motion. After making the
comment and oppositon, this Honorable Court ordered that the
Motion for Reconsideration is already submitted for resolution and
that the tentative for the pre-trial will be on November 12, 2019 at
8:30 in the morning.

3. The undersigned counsel is ready to present the plaintiff’s

evidence on September 24, 2019. However, in order to not pre-empt
this Honorable Court’s pending resolution to the above-mentioned
motion, we are constrained to move for the postponement of the ex
parte presentation of the plaintiff’s evidence.
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4. Additionally, in the event that this Honorable Court denies

the motion, we also pray that the tentative pre-trial set on November
12, 2015 at 8:30 in the morning, be the new date for the ex parte
presentation of the plaintiff’s evidence.

PRAYER

WHEREFORE, Plaintiff prays that the ex parte presentation of

plaintiff’s evidence set on September 24, 2019be cancelled and that
the tentative pre-trial on November 12, 2019, be the new date of the
ex parte presentation of the plaintiff’s evidence should this Honorable
Court denies the Motion for Reconsideration submitted by the
defendant.

Bacolod City. September 21, 2019.

KALALANG and KALALANG LAW OFFICE

Bldg. 2, 69th Floor,
Ayala Super Mega Metro Mall,
Bacolod City, Negros Occidental

By:

ATTY. SALVINO KRISTI S. KALALANG

UNTIL DECEMBER 18, 2019
PTR NO. 696969
IBP NO. 696969
Roll No. 8891
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NOTIFICATION

THE BRANCH CLERK OF COURT

Regional Trial Court, Branch xxx
Bacolod City

Atty. Tony Stark

Counsel for defendants

Greetings:

Please submit the foregoing Motion for Postponement and

approval of the Honorable Court immediately upon receipt hereof.

ATTY. SALVINO KRISTI S. KALALANG

Copy furnished by registered mail:

Atty. Tony Stark

Counsel for defendants
LIttel Angel’s Bldg. Golden Field, Bacolod City

EXPLANATION AS TO MODE OF SERVICE

Pursuant to Section 11, Rule 13 of the Rules of Court, Plaintiff,
through undersigned counsel, manifests that copies of this Motion
had been sent to the afore-stated parties by registered mail, rather
than by the preferred mode of personal service, in view of lack of
personnel and material time.

ATTY. SALVINO KRISTI S. KALALANG