REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

Malolos City, Bulacan
Branch 80

REYNALYN B. EDUARDO-HOSHIYA,
Petitioner,
CIVIL CASE NO. 478-M-2015
-versus FOR: Judicial Recognition of
Foreign Divorce
HIROAKI HOSHIYA,
Defendant.
x--------------------------------------------x

MOTION TO WITHDRAW

Petitioner, by the undersigned counsel, respectfully move to

withdraw as he hereby withdraws his Petition for Judicial Recognition of
Foreign Divorce on the following grounds:

1) That due to the unforeseen circumstances that brought by the

pandemic COVID-19 pertinent documents cannot be presented
to this Honorable Court within a reasonable time;

2) And to unclog this case from this Honorable Court so as not

waste its precious time.

PRAYER

WHEREFORE, on the grounds afore-cited, it is respectfully moved

and prayed of this Honorable Court that the instant petition be ordered
withdrawn.

Other reliefs just and equitable under the premises are likewise
prayed for.

August 25, 2020. City of San Jose del Monte, Bulacan.

WARLITO DM. GOGOLIN
WARLITO DM. GOGOLIN LAW OFFICE
San Francisco St., Brgy. Poblacion I
City of San Jose del Monte, Bulacan
Roll No. 52714
PTR No. 2279808; 1/02/2020; CSJDM, Bulacan
 IBP No. 102535; 1/03/2020; Bulacan
MCLE Comp. VII No. 0002403; 02/13/2020

With my conformity:

REYNALYN B. EDUARDO-HOSHIYA

NOTICE OF HEARING and Copy Furnished to:

THE BRANCH CLERK OF COURT

REGIONAL TRIAL COURT
Malolos City, Bulacan
Branch 80

OFFICE OF THE PROVINCIAL PROSECUTOR

City of Malolos, Bulacan

GREETINGS:

Please submit the foregoing motion for the consideration and approval of
the Honorable Court immediately upon receipt hereof. Thank You.

WARLITO DM.
GOGOLIN

Copy Furnished:

HIROAKI HOSHIYA
Blk 58 Lot 41 Canada St., Harmony Hills
Brgy. Muzon, City of San Jose del Monte, Bulacan

OFFICE OF THE PROVINCIAL PROSECUTOR

City of Malolos, Bulacan

EXPLANATION

In compliance with Rule 13 Section 11 of Rules of Court, service

by registered mail, of the foregoing Motion to the other party was resorted
due to distance and lack of personnel to effect personal service.
 WARLITO DM.
GOGOLIN