Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

Tanjay City

PEOPLE OF THE PHILIPPINES CRIM CASE NO. 7642

Complainant,
FOR: SIMPLE ORAL
---versus--- DEFAMATION

DONNALOU PADA Y REYES

Respondent.
X- - - - - - - - - - - - - - - - - - - - - - - /

MANIFESTATION with
MOTION FOR RESETTING
Comes now, ACCUSED DONNALOU PADA Y REYES, by and
through undersigned counsel, unto this Honorable Court, most
respectfully aver that:

1. After the last hearing held on March 1, 2019, Accused herein

conferred with private complainant to try and settle matters
amicably for after all, they are blood relatives. Thereafter,
Accused had been exerting efforts to reach out to private
complainant and profess her sincere remorse and willingness to
rebuild their relationship as close relatives;

2. Fortunately, private complainant herself expressed her

willingness to accept the heartfelt apology of the Accused and to
eventually reach a settlement that is just for this case;

3. However, with profound regret, the undersigned counsel cannot

make it on the hearing scheduled on March 27, 2019 due to the
fact that on the same day, the undersigned is going to travel by
land from Iloilo to Dumaguete to be able to join the MCLE which
is set on the 28th to the 29th. Regrettably, the undersigned can no
longer defer undergoing MCLE because as a new lawyer
admitted to the BAR on June 4, 2018, the undersigned is required
to complete 12 units of MCLE before April 2019;

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4. In view of the foregoing, the undersigned respectfully prays
unto the Honorable Court that the hearing set on March 27, 2019
be reset to April 05, 2019 or on any date that is convenient to the
calendar of the court;

5. This motion is submitted in utmost good faith and not intended

to delay the proceedings of the instant case.

PRAYER

WHEREFORE, premises considered, it is most respectfully

prayed unto the Honorable Court to reset the March 27, 2019
hearing to April 05, 2019 or on any date that is convenient to the
calendar of the Honorable Court.

Other reliefs, just and foregoing, are likewise prayed for.

RESPECTFULLY SUBMITTED.

21 March 2019 Dumaguete City, Philippines.

ATTY. MARVILIE M. SERNA

PTR No. 2109166A/01-03-2019
IBP No. 067946/01-10-2019
All issued in Dumaguete City, Philippines
MCLE Exempt
Admitted to the BAR on June 4, 2018
Roll No. 70642 (06/04/18)

OFFICE ADDRESS:
Suite 1, 2ND Floor, RM Building
North National Highway cor. East Rovira Road
Dumaguete City
Telephone Number 225-5079/422-7253

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 REQUEST FOR SUBMISSION

The Clerk of Court

MUNICIPAL TRIAL COURT IN CITIES
Tanjay City

Greetings:

Please submit the foregoing Motion to the Honorable Court for

its kind consideration and resolution upon receipt hereof without the
appearance of the undersigned counsel and without further
arguments, unless ordered by the Honorable Court.

Thank you.

ATTY. MARVILIE M. SERNA

Copy furnished:

PROS. JAMES MICHAEL VINCENT J. TINAGAN

Associate Prosecution Attorney II
Tanjay City

*On account of distance, this Manifestation with Motion is served through

private courier instead of personal service for the practicable reasons.

ATTY. MARVILIE M. SERNA

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