REPUBLIC OF THE PHILIPPINES METROPOLITAN TRIAL COURT NATIONAL CAPITAL JUDICIAL REGION PASIG CITY BRANCH 72 SPS. DR. PAUL ED DELA CRUZ ORTIZ and DR. JENNIFER MANINANG ORTIZ, Plaintiffs, CIVIL CASE NO. M- PSG-22- - VS- 03933-CV For: Civil Action for Damages / Breach of Contract BANGKAPRO AQUATICS, INC. and ROMEO T. ORIO and its Officers, FILIPINA RECATO and MARIE C. CANSEKO, Defendants. x ENTRY OF APPEARANCE = With Manifestation and Motion PLAINTIFFS SPS. DR. PAUL ED DELA CRUZ ORTIZ and DR. JENNIFER MANINANG ORTIZ, through undersigned counsel, unto this Honorable Court most respectfully states: 4. The undersigned law firm is entering its appearance as collaborating counsel for the SPOUSES PLAINTIFFS. 2. Henceforth, it is requested that all Orders, Pleadings and all other legal correspondence for the Plaintiffs be furnished them at its address hereinbelow indicated. 3, The undersigned law firm has just been hired this April 16, 2023 to act as collaborating counsel for the Plaintiffs due to the unavailability of the original counsel as she is currently on leave. 4. Due to the lack of time and the present numerous cases being handled by undersigned counsel, she will need to read thru the voluminous documents and records of this case in order to provide a meaningful course of action/recommendation to Plaintiffs’ cause.5. While the undersigned counsel has already read thru the case and filed the necessary Preliminary Conference Brief with coordination from the counsel on record, there are additional documents that need to be submitted. 6. Based thereon, it is respectfully prayed that the kind indulgence of this Honorable Court that the Plaintiff be allowed to present additional evidence by setting an additional hearing date, aside from April 20, 2023, for preliminary conference. PRAYER WHEREFORE, it is most respectfully prayed of this Honorable Court that, the Entry of Appearance be noted. Likewise, it is prayed that the Manifestation and Motion of the Plaintiffs be noted and that an additional hearing date for preliminary conference be set for submission of additional evidence for the Plaintiffs. Quezon City for Pasig City, April 17, 2023. GABRIEL & MENDOZA Law Offices Collaborating Counsel for the Plaintiffs Suite 601, Fil-Garcia Tower, 140 Kalayaan Avenue Cor. Mayaman Street, Diliman, Quezon City (02) 8463-7994; /8928-8817 gabby7112000@yahoo.com By: DAVID/MICHAEL O. GABRIEL Roll of Attorneys No. 44008 IBP No. 298010.February 16, 2023. Quezon City PTR No. 4055215.January 9, 2023.Quezon City MCLE Compliance No. VII-0018020; valid until April 14, 2025 JOCEL ERIAL GABRIEL Roll of Attorneys No. 49468; 05-05-2004; Manila IBP No. 2980088; February 16, 2023. Bulacan PTR No. 5160140; February 8, 2023.Mandaluyong City MCLE Compliance No.VII-0018021: valid until April 14, 2025 0917-8442723 jocxgerial@yahoo.comCopy furnished: Atty. Mario P. Narag, Jr. NARAG LAW OFFICE Counsel for the Defendants Date: Unit 1 Dictum Bldg., Crispina Avenue Las Pinas Village, Pamplona III 1740 Las Pifas City narag.law@gmail.com mfsumira.naraglaw@gmail.com EXPLANATION ON MODE OF SERVICE (Pursuant to Section 11, Rule 13 of the 1997 Rules of Civil Procedure) The foregoing was served and filed by electronic means/LBC/registered mail due to the lack of available manpower who could effect personal service. (Please disregard if personal service has been made.)