Professional Documents
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Petitioner,
-versus-
______________________,
Respondent.
x - - - - - - - - - - - - - - - - - - - - - - - - -x
FOR: _____________________________
Since separation de facto of herein parties, petitioner has not seen nor meet KATHRINE
BERNARDO CORONADO, his daughter with herein respondent. Petitioner’s daughter has been
in the custody of respondent ever since he decided to pack his things and leave the conjugal
abode in December 2003 due to unbearable circumstances.
Efforts to visit his daughter proved exceedingly difficult if not almost impossible on the part of
the petitioner due to herein parties’ personal animosity.
Since the separation de facto of herein parties, petitioner has continued to support to his
daughter by depositing the money in the account of the respondent.
Petitioner wishes to exercise his visitation rights over his daughter. Henceforth, petitioner
proposed to pick up her daughter every other Saturday every month in the mall or residence
of the respondent or any other place designated or agreed upon by herein parties to be
returned on the same day or the next day as agreed upon by both parties.
PRAYER
WHEREFORE, it is respectfully prayed that after due notice and hearing, an order by this
Honorable Court enforcing the visitation right over his daughter be issued in favor of the
petitioner.
Imus City, for Pasay City, January 9, 2014.
by:
____________________________________
Notice
Pasay City
Pasay City
ELLEN A. ADARNA
Greetings:
Please take notice that on Tuesday, 21 May 2013 at 3:00 o clock in the afternoon, or as soon as
counsel may be heard, undersigned shall submit the foregoing urgent motion for the
consideration and approval of this Honorable Court.
Copy furnished:
HON. SOLICITOR GENERAL
Pasay City
ELLEN A. ADARNA
Explanation
The foregoing motion is being filed to the Honorable Court with copy therefore furnished to
the Office of the Solicitor General, Office of the Provincial Prosecutor and to the other party
by registered mails, due to the distance of the undersigned from the said office and other
party, making personal service thereof not practicable.