Republic of the Philippines

Third Judicial Region

OFFICE OF THE CLERK OF COURT
City of Malolos, Bulacan

IN THE MATTER OF
MUNICIPAL ORDINANCE
17-241 ISSUED BY THE
SANGGUNIANG BAYAN
NG BULAKAN, BULACAN

MBBTODA, as herein
represented by EFREN
FRANCISCO,
Petitioners,

-versus- For: Declaratory Relief with Very

Urgent Motion for the Issuance of
a Preliminary Injunction and/or a
Temporary Restraining Order
THE SANGGUNIANG
BAYAN NG BULAKAN,
BULACAN
Respondents.
x- - - - - - - - - - - - - - - - - - -
--x

MOTION FOR SPECIAL RAFFLE

COME NOW, Petitioners, by and through the

undersigned counsel and unto the Honorable Office, most
respectfully states that:
 1. Petitioners are filing this action for Declaratory
Relief with Very Urgent Motion for the Issuance of a
Preliminary Injunction and/or a Temporary Restraining Order
against the Sangguniang Bayan ng Bulakan, Bulacan.

2. Perusal of the case being filed before the

Honorable Office will readily reveal the urgency thereof,
hence, according to the Rules of Court, Petitioners set the
hearing of the Very Urgent Motion for the Immediate
Issuance of a Preliminary Injunction and/or a Temporary
Restraining Order on 13 Friday 2020, otherwise, the
Petitioners will suffer irreparable damage and injury.

3. For this reason, Petitioners hereby move that this

instant case be raffled today, 11 March 2020 so that it may
be heard by the Honorable Court on the hearing set forth in
the motion.

PRAYER

WHEREFORE, premises considered, it is most

respectfully prayed unto the Honorable Court that this
motion be GRANTED and that the instant case BE
RAFFLED TODAY, 11 MARCH 2020.

Such other relief and remedy, as may be available

under the premises, are likewise prayed for.

Balagtas for the City of Malolos, Bulacan.

11 March 2020.

RAMOS LAW OFFICE

Counsel for the Petitioner
 Unit 3, 2nd Floor Jesus Austria Bldg.,
427 Brgy. Wawa, Balagtas, Bulacan

By:

ATTY. FERDINAND RAMOS, CPA

[insert details here]

Notice and Copy Furnished:

SANGGUNIANG BAYAN NG BULAKAN

Municipal Hall Bldg.,
Bulakan, Bulacan

Gentlemen:

Greetings!

Please take notice that the foregoing Motion for Special

Raffle is being submitted to the Honorable Office for
favorable resolution thereof.

ATTY. FERDINAND RAMOS

EXPLANATION
 Due to time constraints, distance and lack of
manpower to effect personal service, a copy of this pleading
was served to the adverse party via private courier.

ATTY. FERDINAND RAMOS