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Urgent Motion For Postponement by JOLO and EDG

This document is a motion filed in Regional Trial Court Branch 212 in Mandaluyong City requesting a postponement of a hearing scheduled for September 26, 2019. The respondents terminated their legal representation and their previous counsel withdrew from the case. As a result, the respondents have not secured new legal counsel to represent them at the scheduled hearing and are requesting the hearing be rescheduled to the last week of November to allow them time to find new representation. Copies of the motion were provided to both the petitioner's counsel and government offices involved in the case.

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121 views3 pages

Urgent Motion For Postponement by JOLO and EDG

This document is a motion filed in Regional Trial Court Branch 212 in Mandaluyong City requesting a postponement of a hearing scheduled for September 26, 2019. The respondents terminated their legal representation and their previous counsel withdrew from the case. As a result, the respondents have not secured new legal counsel to represent them at the scheduled hearing and are requesting the hearing be rescheduled to the last week of November to allow them time to find new representation. Copies of the motion were provided to both the petitioner's counsel and government offices involved in the case.

Uploaded by

Johnime
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION


REGIOAL TRIAL COURT
BRANCH 212
MANDALUYONG CITY

IN RE: PETITION FOR


CANCELLATION OF ENTRY IN
THE CERTIFICATE OF LIVE
BIRTH OF JUAN LORENZO DE
GUIA GODINO,

WILLIAM GO GODINO,
Petitioner,

SP PROC. No. MC14-9346


-versus-

JUAN LORENZO DE GUIA


GODINO, ELIZABETH DE
GUIA, and the LOCAL CIVIL
REGISTRAR OF
MANDALUYONG CITY,
Respondent.
x-------------------------------------------x

URGENT MOTION FOR POSTPONEMENT

RESPONDENT, the undersigned and to this Honorable Court


most respectfully manifests:

1. That the Court issued an Order setting for the initial


presentation of Respondent’s evidence on September 26, 2019 at
2:00 o’clock in the afternoon. (Copy of the Order duly received by the
undersigned is hereto attached and marked as Annex “A”);

2. That respondent loss trust and confidence to their previous


counsel Atty. Jose Ventura Aspiras of Carpio & Bello Law Offices;

3. That by reason of which respondent terminated their legal


relationship with their counsel and to the firm. Atty. Aspiras formally
submits his Withdrawal of Appearance dated September 20, 2019 as
counsel for the respondent. (Copy of the Withdrawal of Appearance
dated September 20, 2019 is hereto attached and marked as Annex
“B”);

4. Unfortunately the respondent, as of the moment has yet to


find a counsel to represent them with the case, hence, no one will
attend to the hearing of the above-captioned case. Thus battle was
left to respondent to fight on their own.

5. That respondent apologizes to the Honorable Court for the


resetting of the case and it is not their intention to delay their
immediate resolution but solely predicated upon the foregoing
reason.

WHEREFORE, premises considered, it is respectfully prayed of


the Honorable Court that the hearing for the initial presentation of
Respondent’s evidence on the above-entitled case on September 26,
2019 at 2:00 o’clock in the afternoon be cancelled and the same be
reset to another day preferably on the last week of November 2019 or
at the convenience of this Honorable Court.

Pasig City, Philippines, September 26, 2019.

By:

JUAN LORENZO DE GUIA GODINO


175 MERCED ST. PACO, MANILA

ELIZABETH DE GUIA GODINO


175 MERCED ST. PACO, MANILA

Copy furnished:

Atty. Maricris B. Pahate


Andres Padernal & Paras Law Offices
Counsel for Petitioner
8th Floor, Saguittarius Office Condominium
No. 111 HV dela Costa Street
Bel Air, Salcedo Village, Makati City
Office of the City Prosecutor
Mandaluyong City

Office of the Solicitor General


134 Amorsolo St., Legaspi Village Makati City

The City Local Civil Registrar


Mandaluyong City

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