Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Quezon City, ____________

Plaintiff,

- versus – CRIM. CASE NO.

Accused.

x--------------------------------------x

URGENT MOTION TO RESET

ACCUSED, through counsel, respectfully states:

1. The Honorable Court in its order dated ______________,

set the pre-trial conference for above-captioned case on
______________, at __________ in the morning;

2. Accused respectfully manifests that he is not available on

the aforementioned date because
________________________________________________________
________________________________________________________
which was scheduled earlier. A copy of the order is hereto
appended as Annex “A”;

3. Accused has utmost respect to the Honorable Court and

sincerely seeks consideration and understanding for his
failure to attend the trial;

4. In consideration of the foregoing, undersigned counsel

humbly and respectfully moves for the deferral and
resetting of the pre-trial conference;

5. This Motion is not intended to delay the proceedings but

solely for the above reasons.

PRAYER

ACCORDINGLY, it is respectfully prayed of the Honorable

Court that the hearing scheduled ____________ at ___________.
be deferred and reset to a date more convenient to the
Honorable Court.

Other just and equitable reliefs are likewise prayed for.

Quezon City. ___________

Assisted by: