Ex-parte motion to reset

In Re’ Petition for Judicial

Recognition of Foreign Marriage
Page 1 of 2
Republic of the Philippines
REGIONAL TRIAL COURT
National Capital Judicial Region
Branch 48, Manila.

IN RE: PETITION FOR JUDICIAL

RECOGNITION OF FOREIGN DIVORCE

CAROL TUASON ICO,

Petitioner,
S.P. Proc. No. 12127214
-vs-

TOSHIKAZU TANAKA & the

LOCAL CIVIL REGISTRAR OF MANILA.
Respondents
x---------------------------------------------------------x

EX-PARTE MOTION TO RESET HEARING

COMES NOW, Petitioner CAROL TUASON ICO, through the undersigned

counsel, unto this Honorable Court, most respectfully alleged and set forth- that:

1. That the above-entitled case is scheduled for hearing on April 21, 2012,
at 8:30 a.m., regarding the Opposition filed by the Office of the Solicitor General;
2. Unfortunately, the undersigned counsel has prior commitment on that
day in the City of Aklan. Such commitment was scheduled way before the Office of
the Solicitor General filed its Opposition. (Attached hereto as Annex “A” is the itinerary
receipt from Cebu Pacific Air);
3. That due to the conflicting schedule, the undersigned counsel could not
possibly attend the hearing on the said motion and there are no other counsel who
could possibly substitute for the undersigned on the said scheduled hearing;
4. That Petitioner through the undersigned counsel, most respectfully ask
the kind indulgence of this Honorable Court that the scheduled hearing set on April
20, 2012 be cancelled and reset preferably on the April 27, 2012 also at the same time;
5. This Motion is not intended in anyway to delay the proceedings of the
instant case but solely dictated by aforesaid circumstances.

PRAYER
 Ex-parte motion to reset
In Re’ Petition for Judicial
Recognition of Foreign Marriage
Page 2 of 2
WHEREFORE, premises considered, it is respectfully prayed that the hearing
of this case scheduled on April 20, 2012 be cancelled and reset preferably on the April
27, 2012 also at the same time.
San Juan City for Manila, 12 April 2012.

THE LAW FIRM OF GARCIA, DAUZ & FETIZANAN

Suite 2306 Atlanta Centre Building, Annapolis St.
Greenhills, San Juan City, M.M.
By:

ATTY. MICHAEL P. DAUZ

Counsel for Petitioner
PTR NO. 0397057/01-13-12/Manila
IBP NO. 884851/01-17-12/RSM
Roll of Attorneys No. 54742
MCLE Compliance No. III-001331
04-21-2010/Manila

NOTICE OF HEARING

G R E E T I N G S:

Please submit the foregoing motion for the consideration and approval of the
Honorable Court immediately upon receipt hereof without further argument.

MICHAEL P. DAUZ
Copy furnished:

OFFICE OF THE CITY PROSECUTOR

City of Manila

OFFICE OF SOLICITOR GENERAL

134 Amorsolo St., Legaspi Village,
Makati City

TOSHIKAZU TANAKA
BLOCK 4, LOT 12 CASIMIRO BAYTOWN
VILLAGE HABAY 1, BACOOR CITY, Cavite

EXPLANATION OF SERVICE

The above Motion was not served personally to the above mentioned parties
and service by registered mail was resorted to due to distance, and lack of the
undersigned’ office personnel thereby rendering personal service thereof
inconvenient and impracticable.

MICHAEL P. DAUZ