Make 1 receiving copy. Tapos dito mo sila ipareceive.

Your honor, it was only last September 14, that the respondent were informed of this
Honorable Court’s order, and the respondent already have prior urgent commitments on
the said date set. Hence, they were not given ample time to prepare by their legal counsel.

The respondent lost trust and confidence to their previous counsel, hence they ask the
former counsel to withdraw their appearance, and they are still looking for a replacement.

You cannot appear strong. Your appearance kahit na hindi ikaw yung respondent. You
sympathize with them. Na parang ikaw yung nagmamakaawa. “Your honor, because, the
respondents were not prioritize, when you issued the order, there should be a _________.

The previous counsel received the order August 28, but the respondent were only
informed a couple days, September 14. Why? From what we found out, they close the
law firm, for several weeks, because the managing partner, went abroad.

To be honest your honor, there were certain instances / circumstances, wherein,

respondent Dra. Godino was the/had to make or draft replies, because she couldn’t get in
touch with her counsel.

Titirahin ka ni private prosecutor, “Delaying tactics.”

Hindi to delaying tactics, we respondent were only informed of the order last September
14, and we had a meeting September 19.

Ito ang iiwasan natin. Malamang may sariling abogado yung local civil registrar. Ok, Dra.
Godino may delay their presentation, but the local registrar may present first.

Kumuha ka muna ng kakampi, yung abogado ng civil registrar. Kausapin mo na sya na

ganito yung gagawin nyo. Kausapin mo si regisrar, “sir ikaw po ba unang magpepresent o
kami.” Try mo ilead sya, Oh supportahan mo ko dito, ireset natin. Magugustuhan niya
yan. Dagdag trabaho sunod sunod diba? Pumunta ka muna kunwari sa clerk of court or
sino man secretary yung nandoon. Kung sino representative ng civil registry.

I’m hear po your honor, number 1 to represent the respondent, because we were only
informed last Semptember 14, because their legal counsel only met with them last
September 19. They were not given the chance to prepare, because of that, because of
previous issues that they had with their legal counsel. They ask to render their legal
counsel to withdraw. And lost trust and confidence, incapacity and incompatibility, with
differences with views and opinions.

Given that, the respondent were not over joy of the performance of their legal counsel, it
resulted to the termination of their attorney-client relationship, prior to presenting the
evidence of the respondent, wherein the respondent cannot finalize the presentation of
evidence because, their previous legal counsel did not supply them with copies of the
case files, or whatever evidences entered. They promised to deliver to us, but up to now,
there is still none.

Case in point, kunin yung kakampi mo si local registrar, yung Sol Gen.
Pag nakausap mo na yung abogado ng civil registrar tanongin mo sya “Atty. Kausapin
naba natin si fiscal? Kasi even if the private prosecutor will go against, the fiscal may
help you.”

Atty. Kailangan ipostponement, ganito naghahanap pa kasi sila ng abogado. Hindi sila
makausap ng abogado, kasi wala silang kopya ng files. Kaya more or less, request ako ng
copies ng case files. Tapos, pasok nung postponement. Stay within the context of the
motion.

Always remember, anything you say may be used against you. Especially there is an SPA.
Answer the question, and enter your appearance, for in their behalf.

For the respondent your honor, I am the representative by virtue of the SPA, if i may give
you a copy. Pagtapos nun dun nila papatatakan.

Palabasin mo nalang na wala kang kaalam alam.

If asked “who are you?” I am the representative by virtue of the SPA issued to me, if i
may submit this to court.

Bakit hindi mo sinubmit ng sept. 20 yan?

They were waiting for Atty. Aspiras, to get the copy of the files. Until now, we were not
given a copy, we were not able to finalize a lawyer who would take the case.

The withdrawal of appearance was made last Sept. 20, but it was received by the
respondent Sept, 24, so they didn’t know if they passed this or not. Which i’m assuming
they did not your honor.

The respondent only got a copy of this, last Tuesday your honor, they had no time to file
it.

Because the respondent had to seek assistance from a friend in creating this motion and
the SPA. The friend does not specialize in this type of cases your honor.

What are your credentials, bakit ikaw yung pinili ni EDG. I am the assistance, working
for Dra.
Because she asked me, due to her prior commitments to her patients.

Balik mo parati yung sa previous counsel.

Why diidn’t the respondent asked first the previous counsel to present prior to
withdrawal. Because the respondent lost trust and confidence.

Mensahero kalang “don’t shoot the messenger.”

Hanap ng kakampi “Atty. Paano ba gagawin natin dito, sasabihin kay fiscal na?”

Ang pasa mo muna SPA.

Syempre papakilala ka,

Number 2 motion for postponement, naka annex withdrawal of appearance.

Dalawa kunin mo dyan, abogado ng civil registry pati abogado ng fiscal.

They were even suppose to send this via postal.

They even opted not to because this will be delivered for 15 working days.

Pag nakuha mo na yung loob ni local registry, siya na magsasalita sayo.

Worse case scenario, be prepared.

Sabihin mo agad, “I’m the representative of respondent by virtue of the SPA. If the court
allows i would like to submit the copy of the SPA.”

Where’s the motion for postponement?

Bakit kayo humihingi ng postponement nanaman?

Because the respondent has lost trust and confidence just apparently they had different
views with their previous counsel. Hence, they ask their previous counsel to withdraw.
And now they are in search of a new legal counsel, however, their previous legal counsel
did not furnish them with copies of the complete case files. Hence, we would like to
request your honor, copies of the necessary documents, motions, pleadings, annexes,
evidence of both the petitioner and respondent. The respondent were left in the dark.

Plus the respondent’s previous counsel didn’t furnish the respondent, the copies of the
Exhibits in the last Formal Entry of Evidence of the Petitioner.
Even our annexes, the respondent don’t know what their legal counsel were talking about.

Awa effect lang ang style.

You appear that you can stand on your own.
I’m the assistant of Dra. I’m an undergraduate.

Always appeal by emotions. Don’t be strong. Pakita mo na kami victim dito.

Kuha ka ng kakampi, kunin sympathy nila.