Professional Documents
Culture Documents
MFDH
MFDH
1. That the above entitled case is set for [*INITIAL] hearing on July 7, 2000;
2. That counsel for defendant is afflicted with influenza and is now under the
medical care of Dr. FLU. A copy of the physician’s certificate under is
hereto attached [*REASONS: STILL COLLATING/STUDYING CASE
AND ITS EVIDENCE, WITNESS IS UNAVAILABLE ETC].
(Notice of Hearing)
(Proof of Service and Explanation)
COMES NOW, PLAINTIFF, thru Counsel unto this Honorable Court most
respectfully alleges:
2. That this motion is not intended to delay any further proceedings of this case
but merely because of the conflict in schedule.
3. That it is hereby requested of this Honorable Court to reset the next hearing
to January 18, 2001 at 8:30 o’clock in the morning.
(Notice of Hearing)
(Proof of Service and Explanation)
JUN BALDOMERO,
Plaintiff,
- versus - CIVIL CASE No. 72987-PSG
For: Annulment and Reconveyance
ANNA SAYSON
Defendant.
x------------------------------------x
1. The services of the undersigned counsel were contracted only today, June 1,
2011 and the filing of an answer to above captioned case will expire on June
10, 2000. However, Defendant is still collating documents and information
relative to the John and Jane Does concerned and will need an additional
period of at least ten (10) days counted from June 10, 2000 within which to
file a responsive answer on behalf of defendant Lydia Cu. [*TEN DAYS IS
ACTUAL TOO LONG, BUT COURT WILL EXERCISE DISCRETION]
2. In this regard, undersigned counsel without wanting to delay this case but
because of other equally pending cases and for the reasons stated above
respectfully requests an additional period of ten (10) days counted from June
10, 2011 within which to file an Answer to the above captioned complaint.
3. At the same time, and for the purposes of brevity/economy, the undersigned
wishes to inform this Honorable Court of his entry as counsel for defendant
Lydia Cu and prays that he be served with processes of this Honorable Court
at the address specified herein below, to wit;
ATTY. RGC
(address)
(Notice of Hearing)
(Proof of Service and Explanation)
MARK TECSON,
Plaintiff,
GREGORIO NIEVES,
Respondent.
x-------------------------------------x
COMES NOW PLAINTIFF, thru Counsel, unto this Honorable Court most
respectfully files this pre-trial brief as follows:
I. PARTIES
II. ADMISSIONS
The identity of Defendant Gregorio Nieves is admitted. The existence of a
permanent structure constructed by Defendant on the property of Plaintiff is
admitted.
III. STIPULATIONS
IV. ISSUES
V. DOCUMENTARY EXHIBITS
VI. WITNESSES
A. The Plaintiff
B. Barangay Authorities
RESPECTFULLY SUBMITTED.
(Notice of Hearing)
(Proof of Service and Explanation)