PLAINTIFF, through undersigned counsel, to this Honorable
Court most respectfully states:
1. In an order dated _________ this case was sent to
Archived, subject for revival upon proper motion.
2. That on _________, undersigned counsel received
Return of Service dated __________, stating that on ___________, herein defendant was served with summons, and up to this time, defendant failed to file her answer or any responsive pleading.
3. Plaintiff is very much interested in pursuing the instant
case and prays for the issuance of an Order reviving the case and to admit the attached Motion to Declare Defendant in Default.
PRAYER
WHEREFORE, premises above considered, it is most
respectfully prayed that an Order be issued reviving the instant case, and admit the attached Motion to Declare Defendant in Default.
Other reliefs just and equitable under the premises are likewise prayed for. Pasay City for Makati City, October 29, 2018.