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REPUBLIC OF THE PHILIPPINES

2nd MUNICIPAL CIRCUIT TRIAL COURT
Poro-San Francisco-Tudela-Pilar
Poro, Cebu

LUNA BANO TRIGGS

Plaintiff,

CIVIL CASE NO. SF-334

-versus – For: Quieting of Title

MARCELINA REYES GONZALES and

HEIRS OF MEDINA REYES PASTIDIO
Namely: KIRBY REYES PASTIDIO and
APRIL ANN REYES PASTIDIO
Defendants,
x ------------------------------------------------- /

URGENT MOTION FOR POSTPONEMENT

COMES NOW, the DEFENDANTS, through undersigned counsel, and

unto this Honorable Court, most respectfully submit this Urgent Motion for
Postponement and humbly avers:

1) That this case was set for hearing on May 27, 2021 at 9’ o’clock in
the morning;

2) That the undersigned counsel could not be present on the said date and
time as he has also an important hearing in RTC Branch 66 in Talisay
City, Cebu;

3) That likewise, it also came to the knowledge of the undersigned that

the next witness for the plaintiff and died;

4)The undersigned respectfully request this Honorable Court for the

resetting of the May 27, 2021 hearing of this case particularly to a
schedule that is most convenient of this Honorable Court;

5)That this Urgent Motion for Resetting is done with utmost sincerity and
good faith and not done for purpose of delaying the proceedings of this
Honorable Court but for reasons above cited;

6)That likewise petitioners humbly apologized for this situation and

undertake to be ready on the next scheduled hearing;

WHEREFORE, in view of the foregoing, it is most respectfully prayed before

this Honorable Court to reset the May 27, 2021 hearing of this case to a schedule
that is most convenient of this Honorable Court;
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Respectfully submitted. May 26, 2021

DAVIDE, SUSUSCO and ASSOCIATES LAW OFFICE

COUNSEL FOR THE DEFENDANTS
Rm. 306 Diaz Bldg., J. Avila St., Capitol Site, Cebu City
By:

ATTY. GIOVANNI D. SUSUSCO

IBP NO. 8852 / 01-17-2020 / CEBU
PTR NO. 503905 / 01-17-2020 / CEBU PROV
Roll of Attorneys No. 53097
Admitted to the Bar on April 26, 2007
MCLE VI-0027317
Email: giosususco@yahoo.com

NOTICE OF HEARING

The Clerk of Court

MCTC - PILAR-PORO-SAN FRANCISCO-TUDELA
Cebu

Greetings: Please submit the foregoing motion for the consideration of the
Honorable Court immediately upon receipt hereof without further oral arguments
and presence of counsels.

ATTY. GIOVANNI D. SUSUSCO

Copy furnished:

ATTY. NELSON MONDIGO

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johneilmoon35@yahoo.com

(Copy furnished by electronic mail due to distance and lack of office personnel)

ATTY. GIOVANNI D. SUSUSCO