Republic of the Philippines

National Capital Region

REGIONAL TRIAL COURT
_____________

_________________,
Plaintiff,
Civil Case No. _______
- versus –

____________________
Defendant.
x--------------------------------------x

ENTRY OF APPEARANCE WITH MOTION TO CONDUCT

VIDEOCONFERENCING HEARINGS

Plaintiff ________________ (“Plaintiff”), by counsel, most

respectfully states the:

I. BY WAY OF APPEARANCE

1. The undersigned counsel respectfully enters its

appearance as counsel for the Plaintiff. Henceforth, it is requested
that all notices and other legal processes of the Honorable Court be
sent at its address as indicated below.

II. BY WAY OF MOTION

2. It is respectfully manifested that the undersigned counsel

was recently engaged by the Plaintiff to represent him in the instant
case.

3. The undersigned counsel further manifests that in the

month of August 2020, the incidence of the Covid 19 disease cases
among the population in Metro Manila is continuing to increasing at
an alarming rate. Thus, in order to avoid the possibility of contracting
the said disease, it is most respectfully prayed that the hearings in the
instant case be conducted via videoconferencing.

PRAYER

WHEREFORE, premises considered, Plaintiff most respectfully

pray unto the Honorable Court that an Order be issued:

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 a) Taking note and making of record the appearance of the
undersigned counsel; and

b) Granting the instant Motion to conduct the subsequent

hearings via videoconferencing.

Other reliefs, just and equitable under the premises, are

likewise prayed for.

Manila City, _________.

______________________________
Counsel for the Plaintiff
__________________________

By:

_______________________

COPY FURNISHED

_________________

Dear Sir/Maam,

It is respectfully requested that the instant Motion be submitted

for the consideration of the Honorable Court upon receipt and
without further hearing.

______________

EXPLANATION

The instant Entry of Appearance with Motion is being filed and

served by way of private courier/electronic mail due to time,
logistics and manpower constraints.

_____________________

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