Republic of the Philippines

COURT OF APPEALS
Manila

ANA MARIA,
Plaintiff-
Appellee,

-versus- CA-G.R. CV NO.

xxxxxx
JOSE MARIA,
Responde
nt,
x-----------------------------------------
-------x

REPUBLIC OF THE
PHILIPPINES,
Oppositor-
Appellant.
x-----------------------------------------
-------x

MOTION TO WITHDRAW
WITH MANIFESTATION

COMES NOW, the undersigned counsel, unto this

Honorable Court of Appeals, most respectfully states that due
to her appointment to the government, where practice of
profession is prohibited, undersigned respectfully requests
that she be allowed by this Honorable Court of Appeals to
withdraw her appearance in this case as counsel for Plaintiff-
Appellee.

Henceforth, undersigned also respectfully requests that

future notices and processes of this Honorable Court of
Appeals, and pleadings, motions and correspondence from the
other party in this case be sent directly to the Plaintiff-
Appellee at her address at #xxx, xxx street, xxx City.

Further, it is respectfully manifested that in compliance

with the Order of this Honorable Court of Appeals in its
Resolution dated xx July 20xx, received by the undersigned on
xx September 20xx, the undersigned humbly beseech the
understanding and consideration of this Honorable Court that
due to personal and professional problems of being a solo
practitioner, coupled with the fact that she was about to start
a new job, the undersigned was unable to keep track of the
cases she used to handle.

However, to show proof that the adversary parties

received copies of the Appellee’s Brief sent on xx February
20xx, the undersigned counsel submits the registry return
receipts to wit:

Registry Receipt Addressed to Received by Date

No. Received
RD xxx xxx xxx Office of the Solicitor Docket xx March
ZZ General Management 20xx
Oppositor-Appellant Service
RD xxx xxx xxx Jose Maria xxx xx March
ZZ Respondent 20xx

PRAYER

WHEREFORE, premises considered, undersigned

counsel prays that she be allowed to withdraw her appearance
in the above-captioned case and that future notices and
processes of this Honorable Court of Appeals, and pleadings,
motions and correspondence from the other party in this case
be sent directly to the Plaintiff-Appellee at her address at #xxx,
xxx street, xxx City and that the undersigned be relieved from
all responsibilities relative to this case.

Further it is also prayed that the explanation for her

failure to submit proof that the adversary parties received
copies of Appellee’s Brief be duly accepted and that the said
Appellee’s Brief be admitted and considered by this Honorable
Court of Appeals in the resolution of this case.

Other reliefs just and equitable under the premises are

likewise prayed for.

RESPECTFULLY SUBMITTED.

Xxx City for Manila. xx September 20xx.

ATTORNEY XXX
Counsel for Plaintiff-Appellee
Roll No. xxxxxx
PTR No. xxxxxx
IBP No. xxxxxx

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 MCLE Compliance No. xxxxxx

NOTICE OF HEARING

CLERK OF COURT
Court of Appeals
Manila

Greetings!

Kindly submit the foregoing Motion to Withdraw with

Manifestation for the approval of this Honorable Court of
Appeals immediately upon receipt thereof.

ATTORNEY XXX

COPY FURNISHED:
OFFICE OF THE SOLICITOR GENERAL RR
No.______________
134 Amorsolo Street, Legaspi Village XXX City
Makati City 1229
JOSE MARIA RR
No.______________
#xxx, xxx Street XXX City
Xxx City

EXPLANATION

In compliance with Section 11, Rule 13 of the Rules of

Court, the foregoing pleading is being served by registered
mail, it being impracticable to serve the same by personal
service due to time constraints and the lack of messengers to
effect the personal service thereof.

ATTORNEY XXX

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