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PRAYER
WHEREFORE, defendant most respectfully prays that an order be issued by this
Honorable Court requiring the plaintiff to make more definite statement as to the
particulars of the check mentioned in paragraph 5 of his complaint, particularly stating
its amount, check number, date, and the name of the drawee bank.
Quezon City, Philippines, January 23, 2014
ATTY. ROMMELITO FRANCISCO
MACARAYO
counsel for the defendant
13-69 Barracks Building, Marikina
IBP NO. 87123-7/19/12-AC
PTR NO. 669913/21/12-AC
Roll No. 99998
MCLE Exempt
(Admitted to the bar: April 6, 2012)
NOTICE OF HEARING
Atty. Ezekiel Razon
Counsel for the Plaintiff
12-26 Marina Arcade, Mabalacat City
Greetings! Please take notice that the foregoing Motion for Bill of Particulars shall
be submitted for the consideration and approval of the Honorable Court on Friday,
January 24, at 10:00 AM or as soon as counsel and matter may be heard.
Atty. Rommelito Francisco Macarayo
EXPLANATION
The foregoing Motion for a Bill of Particulars is being filed with this Honorable
Court and served on the opposing counsel by registered mail in view of the
impracticability of personal filing and service due to distance considering that the office
of this Honorable Court is at Quezon City and that of the opposing counsel is at
Mabalacat City, while undersigned counsel holds office in Marikina.
Atty. Rommelito Francisco Macarayo
COPY FURNISHED:
Atty. Ezekiel Razon
Counsel for the Plaintiff
12-26 Marina Arcade, Mabalacat City
-versusPEDRO CRUZ,
Accused.
x----------------------------------------------------x
URGENT MOTION FOR POSTPONEMENT
COMES NOW, the undersigned counsel for the defendant and unto this
Honorable Court, most respectfully manifests:
1.
That a notice of hearing for the above titled case was received by the undersigned last
November 7, 2007 informing the undersigned for the scheduled hearing on November
21, 2007, 8:30 oclock in the morning. (Machine copy of the notice duly received by
the undersigned is hereto attached and marked as annexA);
2.
That on November 6, 2007, a day prior to the date when the abovementioned notice
was received, the undersigned counsel also received a another notice of hearing
scheduled on the same date, November 21, 2007, 8:30 oclock in the morning in a case
for Theft entitled People of the Philippines vs. John Doe filed by the City Prosecutor
of Valencia City docketed as Criminal Case No. 001, for which case the undersigned is
a counsel for the defendant. (Machine copy of the notice of hearing 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 November 21,
2007, 8:30 oclock 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 paragraph
2 of this motion, the notice of which was received by the undersigned ahead of the
notice of the above titled case, on November 6, 2007.
WHEREFORE, premises considered, it is most respectfully prayed to this
Honorable Court that the scheduled hearing pf the above-entitled Criminal case on
November 21, 2007, 8:30 o clock in the morning be please cancelled and reset to
December 10, 2007 at 10:00 oclock in the morning.
Respectfully prayed for.
Doc. No.
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Page No.
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Book No.
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Series of 2013
THIAGO SILVA
NOTARY PUBLIC
Until December 31, 2013
PTR No. 906760 - Jan. 3, 2013
IBP No. 918300
Roll No. 13466