This document is a motion for postponement filed in the Municipal Trial Court of Tacloban City. The motion requests to postpone a hearing scheduled for March 2, 2015 regarding a civil collection case due to a scheduling conflict with a criminal case in which the counsel is also involved. Specifically, the motion notes that the counsel received notice of the criminal case hearing first and must prioritize that case on the scheduled date. It requests that the civil case hearing be rescheduled to March 23, 2015.
This document is a motion for postponement filed in the Municipal Trial Court of Tacloban City. The motion requests to postpone a hearing scheduled for March 2, 2015 regarding a civil collection case due to a scheduling conflict with a criminal case in which the counsel is also involved. Specifically, the motion notes that the counsel received notice of the criminal case hearing first and must prioritize that case on the scheduled date. It requests that the civil case hearing be rescheduled to March 23, 2015.
This document is a motion for postponement filed in the Municipal Trial Court of Tacloban City. The motion requests to postpone a hearing scheduled for March 2, 2015 regarding a civil collection case due to a scheduling conflict with a criminal case in which the counsel is also involved. Specifically, the motion notes that the counsel received notice of the criminal case hearing first and must prioritize that case on the scheduled date. It requests that the civil case hearing be rescheduled to March 23, 2015.
COMES NOW, the undersigned counsel, unto the Honorable Court, most respectfully manifests: 1.That a notice of hearing for the above captioned case was received by the undersigned last February 3, 2015 informing the undersigned for a scheduled hearing on March 2, 2015 at 8:30 o'clock in the morning (machine copy of the notice duly received by the undersigned is hereto attached and marked as ANNEX "A"); 2.That on February 2, 2015, a day prior to the date the abovementioned notice was received, the undersigned counsel also received another notice of hearing scheduled for March 2, 2015 at 8:30 o'clock in the morning in a case for Slight Physical injuries filed by the City Prosecutor of Tacloban City in Criminal Case No. 2015-2, for which the undersigned is a counsel for the defendant (machine copy of the notice duly received by the undersigned is hereto attached and marked as ANNEX "B"); 3.That there is therefore a conflict of schedule for the hearing scheduled on March 2, 2015, at 8:30 o'clock in the morning for the two (2) cases handled by the undersigned counsel; 4.That the undersigned counsel is constrained to appear on the case cited in par. 2 of this motion, the notice of which was received by the undersigned ahead of the notice of the above titled case, on February 2, 2015. PRAYER
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WHEREFORE, premises considered, it is most respectfully
prayed to this Honorable Court that the scheduled hearing of the above captioned case on March 2, 2015 at 8:00 o'clock in the morning be please cancelled and reset to March 23, 2015 at 2:00 o'clock in the afternoon. 23 February 2015, Tacloban City, Philippines. by Castroverde, Leonida, Enabore, Piga and Associates (C.L.E.P.) Law and Accounting Offices Counsel for Plaintiff Suite 007, 2nd Floor, S&A Realty Building 221 Avenida Veteranos , Tacloban City Tel. No. (053) 321-5180/09399267777 E-mail: clep.law@gmail.com ATTY. VINCENT Q. PIGA Counsel for Plaintif Roll No. 5001 IBP No. 012 Lifetime PTR No. 77 - 1/2/14 Leyte MCLE Compliance IV No. 001235 Issued on January 12, 2013 REQUEST ATTY. A.R.P. Clerk of Court III Branch 8, Tacloban City Greetings! Respectfully submitting the foregoing Motion for Postponement for the consideration of this Honorable Court. VINCENT Q. PIGA
PROOF OF REGISTERED MAIL SERVICE
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Copy furnished through registered mail
ATTY. A.R.P. Clerk of Court III Branch 8, Tacloban City Registry Receipt No.:___________________ Post Office:____________________ Date:___________________ ATTY. D.S. Counsel for Defendant D.S.M. Building, 222 Veteranos Ave., Tacloban City Tacloban City Registry Receipt No.:___________________ Post Office:____________________ Date:___________________ EXPLANATION The foregoing MOTION FOR POSTPONEMENT was served to Atty. A.R.P by registered mail instead of personal service for lack of personnel who can effect personal service. VINCENT Q. PIGA