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REPUBLIC OF THE PHILIPPINES

12th Judicial Region


REGIONAL TRIAL COURT
Branch 13
Cotabato City

ELIAS SANCHEZ, CIVIL CASE No. 2019-12-28


Petitioner,
For:
- versus –
DECLARATION OF NULLITY OF
EMMA BONAOBRA-SANCHEZ, MARRIAGE
Respondent.
x--------------------------------x

EX PARTE MOTION TO SET CASE FOR PRE-TRIAL

Petitioner, by undersigned counsel and unto this Honorable Court,


respectfully states:

1. On January 08, 2020, undersigned received a copy of


Respondent's Answer in this case;

2. Considering that a Reply to the said Answer is no longer


necessary due to the fact that said Answer does not raise
any new or substantial issue, or raise issues which should
more properly be addressed during the trial proper, the said
Answer is therefore the last pleading contemplated by the
Rules of Court;

3. As such, undersigned respectfully requests that the instant


case be immediately set for pre-trial.

WHEREFORE, it is respectfully prayed that the instant case be


immediately set for pre-trial, pursuant to Rule 18 of the Rules of Court.

Other relief just and equitable are likewise prayed for.

Cotabato City, Philippines, January 10, 2020.

ATTY. CAMILA DELA TORRE


Counsel for the Petitioner
Door 1, AAA Building, Sinsuat Avenue

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9600 Cotabato City
Roll of Attorney No. 12345
MCLE Compliance No. V-0098765 valid until 4/20/2022
PTR No. 246810/01.04.20/Cotabato City
IBP Lifetime Member No. 078910

NOTICE

THE CLERK OF COURT


Regional Trial Court
Branch 13
Cotabato City

ATTY. JACK THOR S. SPARROW


Counsel for the Respondent
Block 69 Governorsillo Street, RH-7
9600 Cotabato City

GREETINGS:

Please take notice that the Petitioner will submit the foregoing Motion
for the kind consideration and resolution of the Honorable Court
immediately upon receipt hereof.

ATTY. CAMILA DELA TORRE

EXPLANATION

The foregoing Motion was filed with this Honorable Court by registered
mail on account of time constraints.

Copy furnished:

ATTY. JACK THOR S. SPARROW


Counsel for the Respondent
Block 69 Governorsillo Street, RH-7
9600 Cotabato City

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