**CAPTION

MOTION FOR POSTPONEMENT/DEFERMENT HEARING

COMES NOW Defendant, thru undersigned counsel, unto this Honorable

Court respectfully states:

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].

WHEREFORE, it is respectfully prayed that the hearing set on July 7, 2000

be reset to another day preferably on the first week of August 2000 or at the
convenience of this Honorable Court.

Manila, Philippines, July 2, 2000.

Sgd. ATTY. LAA

Counsel for the Defendant

(Notice of Hearing)
(Proof of Service and Explanation)

Republic of the Philippines

REGIONAL TRIAL COURT
Fifth Judicial Region
Branch 13, Ligao City

JUAN DELA CRUZ,

Plaintiff,
- versus - CIVIL CASE NO. 2402
JUANA DELA CRUZ,
Respondent.
x-------------------------------------x

MOTION TO RESET HEARING

COMES NOW, PLAINTIFF, thru Counsel unto this Honorable Court most
respectfully alleges:

1. That undersigned Counsel for Plaintiff has conflict of hearing on December

18, 2000 at NLRC Calamba City which was set earlier than this Court’s
setting.

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.

WHEREFORE, it is hereby respectfully prayed of this Honorable Court to

grant Motion to Reset Hearing from December 18, 2000 to January 18, 2001.

Quezon City for Ligao City, November 29, 2000.

Sgd. ATTY. LAA

Counsel for the Plaintiff

(Notice of Hearing)
(Proof of Service and Explanation)

REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT
National Capital Judicial Region
Branch 265, Pasig City

JUN BALDOMERO,
Plaintiff,
- versus - CIVIL CASE No. 72987-PSG
For: Annulment and Reconveyance
ANNA SAYSON
Defendant.
x------------------------------------x

MOTION FOR EXTENSION OF TIME

TO FILE ANSWER/FORMAL ENTRY OF APPEARANCE

COMES NOW Defendant, thru counsel, unto this Honorable Court,

respectfully avers that:

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)

WHEREFORE, premises considered, it is respectfully prayed that the

foregoing Motion for Extension of Time and Formal Entry of Appearance of the
undersigned counsel be favorably considered.

Quezon City for Pasig City, June 1, 2000.

Sgd. ATTY. RGC

Counsel for the Defendant

(Notice of Hearing)
(Proof of Service and Explanation)

**CONTENTS OF THE BRIEF WOULD DEPEND ON WHAT HAS BEEN

PRESENTED IN THE COMPLAINT AND ANSWER OF THE PARTIES

Republic of the Philippines

REGIONAL TRIAL COURT
Fifth Judicial Region
Branch 13, Ligao City

MARK TECSON,
Plaintiff,

- versus - CIVIL CASE NO. 1567

GREGORIO NIEVES,
Respondent.
x-------------------------------------x

PRE-TRIAL BRIEF OF THE PLAINTIFF

COMES NOW PLAINTIFF, thru Counsel, unto this Honorable Court most
respectfully files this pre-trial brief as follows:

I. PARTIES

Plaintiff is willing to entertain the proposal of the Defendant to amicably settle

this case.

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

The property is declared in the name of Pedro Tecson, married to Corazon

Reyes. The Plaintiff inherited the property from his parents; therefore, the possession
of Plaintiff began from the possession of their parents passed on to them thru
inheritance.

IV. ISSUES

A. Whether or not the property belongs to Plaintiff by inheritance.

B. Whether or not the Defendant is a pretender to the rights of ownership and

possession by the Plaintiff.

C. Whether or not Plaintiff is entitled to damages and attorney’s fees.

V. DOCUMENTARY EXHIBITS

1. Special Power of Attorney

2. Extra Judicial Settlement of Estate
3. Affidavit of Publication
4. Estate Tax Return and Receipts
5. Tax Declarations
6. Death Certificates of Pedro Tecson and Corazon Reyes
7. Birth Certificate of Plaintiff
8. Demand Letter
9. Affidavits

VI. WITNESSES

A. The Plaintiff

B. Barangay Authorities

C. A long time neighbor

D. More or less 5 witnesses in at least eight (8) settings

VII. TRIAL DATES

 As will be mutually agreed upon during the pre-trial conference between the
parties

RESPECTFULLY SUBMITTED.

Sgd. ATTY. RGC

Counsel for the Plaintiff

(Notice of Hearing)
(Proof of Service and Explanation)