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REPUBLIC OF THE PHILIPPINES

FOURTH JUDICIAL REGION


REGIONAL TRIAL COURT
BRANCH 101
STA. ROSA CITY, LAGUNA

IN THE MATTER OF APPLICATION


APPLICATION FOR THE ISSUANCE
OF A WRIT OF HABEAS CORPUS,

JAY HAROLD SALIENTE, for and in


behalf of his minor child, JANELLE
ANDI J. SALIENTE,
Petitioner,

- versus - Spec. Pro. No. 0060-SRCL

PRISCILLA JARLIGO BERNASOR,


Respondent.
x- - - - - - - - - - - - - - - - - - - - - - - - - - - - -x

MOTION TO RESET HEARING


with MANIFESTATION

PETITIONER, by the undersigned counsel, to this Honorable Court, most


respectfully states that:

1. The Notice of Hearing for the above-mentioned case was received


through email. The case was set for hearing on the Application for
Issuance of the Writ of Habeas Corpus via video conference on August
10, 2021 at 1:30 pm;

2. However, we are requesting this Honorable Court to require the minor


child, JANELLE ANDI J. SALIENTE, be brought to this Honorable
Court as she will be presented as witness in the above-mentioned case
and it may be possible that she will be coached by the person/s having
custody of her;

3. With this, the undersigned is constrained to respectfully request the


Honorable Court to reset the hearing of the instant case to another date,
subject to the availability of the Honorable Court’s calendar;

4. This motion is made in good faith and not intended to delay the
proceedings of the instant case.

PRAYER

WHEREFORE, premises considered, and in the higher interest of justice, it is


most respectfully prayed to this Honorable Court that the minor child, JANELLE
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ANDI J. SALIENTE, be brought to this Honorable Court and reset the hearing of
the instant case to another date, subject to the availability of the Honorable Court’s
calendar.
Other relief just and equitable are likewise prayed for.

Cavite City, for Sta. Rosa, Laguna. August 4, 2021.

By:

ATTY. NEMUEL RESURRECCION CAMARSE


Counsel for the Petitioner
LGM Bldg., P. Burgos Ave. cor. Crisostomo St.,
Caridad, Cavite City, Cavite Province
Mobile: 09177755128
Email: coycamarse1008@gmail.com
Roll No.: 69395
IBP No.: 162141 / 07.07.21
PTR No. 8968122 / 02.17.21
MCLE No. VI-0012083

NOTICE OF HEARING

To: Branch Clerk of Court


RTC Br. 101, City of Sta. Rosa, Laguna

Warmest greetings! Please take note that the foregoing Motion shall be
submitted for the consideration and approval of the Honorable Court on
immediately upon receipt hereof.

ATTY. NEMUEL RESURRECCION CAMARSE

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