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Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES


Second Judicial Region
Province of
City of

PEOPLE OF THE
PHILIPPINES,
Plaintiff,
Crim. Case No.
-versus-
For: Violation of P.D. 1612
Accused.
x--------------------------------------x

MOTION TO TRANSFER DATE OF HEARING

THE ABOVE-NAMED ACCUSED, through counsel and


unto this Honorable Court, most respectfully requests for the
resetting of the hearing of the above-entitled case from December
13, 2018 at 8:30 o’clock in the morning to January 14, 2019 at
8:30 o’clock in the morning.

The request for resetting was due to the fact that the
undersigned counsels have to attend previously scheduled hearings
that were set earlier on the same date in the following cases:

REGIONAL TRIAL COURT, BRANCH:

a. People of the Philippines v.. al.; and


b. People of the Philippines v..

REGIONAL TRIAL COURT, BRANCH:

a. People of the Philippines v.;


b. People of the Philippines v.

MUNICIPAL TRIAL COURT IN CITIES,:

a. People of the Philippines v

Considering the foregoing, the undersigned counsels


respectfully move that the hearing of the above-captioned case be
reset to January 14, 2019 at 8:30 o’clock in the morning.

This motion is not intended to delay the proceedings in this


case, but solely for the purpose above-mentioned.

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PRAYER

WHEREFORE, in view of the foregoing, it is most respectfully


prayed that the hearing of the above-entitled case be transferred to
from December 13, 2018 at 8:30 o’clock in the morning to
January 14, 2019 at 8:30 o’clock in the morning.

Santiago City for Cauayan City, Isabela. 6 December 2018.

DELA CRUZ & ASSOCIATES LAW OFFICES


Counsel for the Accused
No. 8 Maharlika Highway, Dubinan East
Santiago City
Tel No. (078) 305-0891
E-mail: JRSDC_STGO@yahoo.com

By:

FRITZGERALD ACE S. PALAC

NOTICE OF HEARING:

HON.
Assistant City Prosecutor
Office of the City Prosecutor
Cauayan City, Isabela

MR.
Municipal Trial Court in Cities
Cauayan City, Isabela

HON.
Cauayan City Parole and Probation Office
Cauayan City, Isabela

Greetings: Please take notice that the undersigned counsel shall


submit the foregoing motion for the kind consideration and
resolution of the Honorable Court on 13 December 2018 at 8:30
o’clock in the morning without further oral argument and even
without the presence of the undersigned. Thank you.

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FRITZGERALD ACE S. PALAC

Copy furnished:
Assistant City Prosecutor
Office of the City Prosecutor
Cauayan City, Isabela
*By registered mail

MR.
Clerk of Court IV
Municipal Trial Court in Cities
Cauayan City, Isabela
*By registered mail

HON.
Cauayan City Parole and Probation Office
Cauayan City, Isabela
*By registered mail

EXPLANATION

Copies of the foregoing Motion to Transfer Date of Hearing


were served to the Office of the City Prosecutor of Cauayan City,
Isabela, to the Office, Cauayan City, Isabela and to this Honorable
Court through registered mail with return card on account of the
impracticability of effecting personal service due to lack messengerial
personnel and distance constraint.

FRITZGERALD ACE S. PALAC