REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 208
Mandaluyong City

ELLEN Civil Case No. 1434414344

Petitioner For Temporary Protection Order

-versus-

JOHN LLOYD
Respondent
X------------------------X

MOTION FOR NEW TRIAL

COMES NOW, the defendant John Lloyd, through the undersigned counsel
and unto this Honorable Court, most avers:

1. That, the judgment of this court in the above-entitled petition was

served on him on February 3, 2021, which was obtained by the plaintiff through
FRAUD when she told the respondent that she is willing to reconcile with him and
starting dating again, and if he learns of the same he has just not ignore the schedule
of hearing.

2. That, since then, respondent in hopes and believes the reconciliation

offer by petitioner Ellen, he decided that the answer not to be filed anymore.
Because of fraud by petitioner, respondent convinced the good heart of Ellen,
without knowing that petitioner appeared before this Honorable Court and testified.
If respondent filed his answer it would alter the outcome of the petition;

3. That the above-mentioned FRAUD as newly discovered evidence

consist of the following, to wit:

a. Text message of petitioner Ellen

b. Affidavits of witnesses
c. Pictures of spouses Ellen and John Lloyd
d. Sweet Facebook post of couple while the petition is
ongoing.

4. That the affidavits of JUAN DELA CRUZ and DEREK RAMPAGE to

substantiate the aforementioned FRAUD by petitioner. (Attached herewith
affidavits marked as Annex-1 and Annex-2 made an integral part of this Motion
 5. That the said FRAUD evidence, if presented this case would change
the outcome of the petition.

WHEREFORE, respondent prays that the judgement in this case be set aside
and new trial be ordered for the reception of the fraud evidence mentioned above.

Other relief and remedies as may be deemed just and equitable under the
premises are likewise prayed for.

Mandaluyong City, February 04, 2021.

REGLO AND ASSOCIATES

Counsel for the Defendant
143 Hulo Bldg,
Maysilo, Mandaluyong City

By: (SIGNED)
KRIZALDY REGLO
IBP No. 1434344
PTR No. 14343445678
MCLE No. V 5555555
Roll No. 1111111111

NOTICE OF HEARING

TO: ATTY JINNY MARCELO

Counsel for Plaitiff/Petitioner

GREETINGS:

Please submit the foregoing motion for the consideration and approval of the
Honorable Court on February 12, 2021, at 2:00 P.M.

(SIGNED)
ATTY. KRIZALDY REGLO
 VERIFICATION

REPUBLIC OF THE PHILIPPINES …)

CITY OF MANDALUYONG ………….…) S.S.

I, Mr. John Lloyd, of legal age, Filipino citizen, married and resident of No. 1234
barangay Hulo, Mandaluyong City, after having been duly sworn to in accordance
with the law do hereby depose and say:

1. That I am the defendant/respondent in the above-entitled case:

2. That I have caused the preparation of the forgoing Motion for New Trial and
have read the allegations contained therein:
3. The allegation in the said complaint are true and correct of my own
knowledge and authentic records.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 4th day of

February 2021, in the City of Mandaluyong.

(SIGNED)
JOHN LLOYD

SUBSCRIBED AND SWORN to before me this 4th day of February 2021, in

the City of Mandaluyong, affiant exhibit to me her Comm. Tax Cert. No. 12345issued
at Mandaluyong City on February 2, 2021.

Doc. No. ___________;

Page N._____________;
Book No. ___________;
Series of 2021

CC: ATTY JINNY MARCELO

Counsel for Plaintiff
23 8th floor Shaw Blvd
Mandaluyong City.