REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

__ JUDICIAL REGION
BRANCH ___

______________________________
Plaintiffs,

Civil Case No. ____________

-v e r s u s-
FOR: REPLEVIN
_______________________________
Defendants.
X - - - - - - - - - - - - - - - - - - - - -X

MOTION TO POST SURETY BOND

Plaintiffs, through the undersigned counsel, unto this Honorable

Court most respectfully state:

1. Plaintiffs filed this Complaint, as it is very clear and it has

been duly established that the apprehension and seizure of the
___________, is illegal and there is an urgent and paramount necessity for
the issuance of the said writ to avoid further serious damage;

2. That it is the desire of the plaintiffs to post surety bond in double

the value of the property;

3. That it would be advantageous to the plaintiffs if the aforesaid

______ be returned or released to them;

3. Since the plaintiffs cannot obtain the amount of bond in cash

due to scarce resources, they intended to undertake an agreement with
any bond issuing company duly accredited by the Supreme Court in
accordance to Rule 60 of the Revised Rules of Court for the
release/return of the aforesaid ___________;
 WHEREFORE, it is most respectfully prayed of this Honorable
Court to grant this motion and order the posting of surety bond instead
of cash bond for the release of the ____________. Other reliefs just and
equitable under the premises are likewise prayed for.

____________, Philippines,
______________.

________________________________
counsel

NOTICE OF HEARING

The Clerk of Court

Branch ____
_________

Greetings!

Please submit the foregoing motion for resolution and approval of

the Honorable Court immediately upon receipt hereof without further
oral argument and appearance.

________________________________
counsel

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