Plaintiff, by counsel and unto this Honorable Court,
respectfully states:
1. The records of the Honorable Court show that Defendant
was served with copy of the summons and of the complaint, together with annexes thereto on _____________;
2.Upon verification however, the records show that
Defendant Joseph L. San Pedro has failed to file his Answer within the reglementary period specified by the Rules of Court despite the service of the summons and the complaint;
3.As such, it is respectfully prayed that Defendant Joseph L.
San Pedro be declared in default pursuant to the Rules of Court and that the Honorable Court proceed to render judgment as the complaint may warrant. PRAYER WHEREFORE, it is respectfully prayed that Defendant Joseph L. San Pedro be declared in default pursuant to the Rules of Court and that the Honorable Court proceed to render judgment as the complaint may warrant. Other relief just and equitable are likewise prayed for. City of Malolos, Bulacan, Philippines, __Date__. By:
KHRISTIENNE RIAN C. BERNABE
Counsel for Plaintiff Address: Blk. 20, Lot 07, Rhodonite St. Rocka Village II, Tabang, Plaridel, Bulacan IBP NO. 1234510: 01-03-20:Malolos City PTR No. 9876543: 01-03-20: Malolos City ROLL OF ATTORNEY No. 510150 MCLE COMPLIANCE No. V-0005101, 01-03-20 NOTICE OF HEARING HON. CLERK OF COURT BR. 1
Greetings.
Kindly bring the foregoing motion to the attention of the
Honorable Court immediately upon receipt thereof and set the same for hearing on ___ day of ___ 2020, 8:30 A.M.
KHRISTIENNE RIAN C. BERNABE
Counsel for Plaintiff Address: Blk. 20, Lot 07, Rhodonite St. Rocka Village II, Tabang, Plaridel, Bulacan IBP NO. 1234510: 01-03-20:Malolos City PTR No. 9876543: 01-03-20:Malolos City ROLL OF ATTORNEY No. 510150 MCLE COMPLIANCE No. V-0005101, 01-03-20
Please be notified that the foregoing motion will be set for
hearing this _____ day of February 2017, 8:30 A.M.
COPY FURNISHED:
KHRISTIENNE RIAN C. BERNABE
Counsel for Plaintiff Address: Blk. 20, Lot 07, Rhodonite St. Rocka Village II, Tabang, Plaridel, Bulacan IBP NO. 1234510: 01-03-20:Malolos City PTR No. 9876543: 01-03-20: Malolos City ROLL OF ATTORNEY No. 510150 MCLE COMPLIANCE No. V-0005101, 01-03-20
RECEIVED BY:
ATTY. Rose F. Bulaklak
Counsel for the Respondent Guiguinto, Bulacan Philippines