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SPECIAL POWER OF ATTORNEY

KNOW ALL MEN BY THESE PRESENTS:

I, JUAN DELA CRUZ, of legal age, Filipino, with address at


_____________________, do hereby appoint, name, constitute, and make
_________________ and/or any of its lawyers, with office address at
__________________________, to be my true and lawful Attorney-in-Fact in the case
entitled “_________________________”, docketed as _______________________, and
pending before ____________________ (“Subject Case”), with full power and authority
to do and perform any or all of the following acts, to wit:

1. To prepare, verify, sign and file such pleadings, motions,


documents and/or papers in the Subject Case;

2. To file any appeal, special civil action, petition, or any other


action before the appropriate courts and/or administrative agencies in order
to question any adverse ruling that may be rendered in the Subject Case;

3. To represent me at any and all stages of the proceedings in the


Subject Case, including at the Pre-Trial or Preliminary Conference thereof, as
well as any and all appeals or petitions arising therefrom;

4. To negotiate and enter into an amicable settlement, compromise


agreement, or plea bargaining agreement, under such terms and conditions
as the said Attorney-in-Fact may deem just and reasonable, without need of
further approval by or notification on my behalf;

5. To submit to alternative modes of dispute resolution, including


mediation and judicial dispute resolution;

6. To agree to the simplification of issues;

7. To file and amend pleadings;

8. To make and obtain stipulations or admissions of facts and of


documents to avoid unnecessary proof;

9. To limit the number and identification of witnesses and the


setting of trial dates;

10. To agree to a preliminary reference of issues to a commissioner;

11. To agree to rendering judgment on the pleadings, summary


judgment, or a dismissal of the action should a valid ground therefore be
found to exist;

12. To make and obtain waivers of objections to admissibility of


evidence;

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13. To agree to avail of the discovery procedures under the Rules of
Court;

14. To agree to a suspension of the proceedings;

15. To agree to modify the order of the trial if the accused admits
the charge but interposes a lawful defense;

16. To mark the evidence of the parties for identification, if not yet
marked in the judicial affidavits of their witnesses;

17. To examine and make comparisons of the adverse parties’


evidence vis-à-vis the copies to be marked;

18. To stipulate regarding the faithfulness of the reproduction and


the genuineness and due execution of the adverse parties’ evidence and
manifesting the same for the record;

19. To reserve evidence not available at the pre-trial by: (i) giving
the name or position and the nature of the testimony of the proposed
witness in cases of testimonial evidence; and (ii) by giving a particular
description of the documentary or object evidence;

20. To do and agree on such matters as will promote a fair and


expeditious trial of the criminal and civil aspects of the case; and

21. To do and perform any and all other acts and things necessary
and proper to be done in and about the premises as fully to all intents and
purposes as they might or could lawfully do if personally present.

HEREBY GIVING and GRANTING unto _____________________ and/or any of its


lawyers, full power and authority to do and perform all and every act and thing
whatsoever required and necessary or proper to be done in and about the premises,
and HEREBY RATIFYING and CONFIRMING all that said attorney-in-fact has done or shall
lawfully do by virtue of these presents.

IN WITNESS WHEREOF, I hereunto affix my signature this __ day of ___________


2020 at __________ City, Metro Manila.

JUAN DELA CRUZ

[JURAT]

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