REPUBLIC OF THE PHILIPPINES

FIRST JUDICIAL REGION

REGIONAL TRIAL COURT
Branch 19
BANGUI, ILOCOS NORTE

IN RE: PETITION FOR THE SPEC. PRO NO. 3007-19

ADOPTION OF THE MINOR
BRIX CYRUZ CALPITO,

SPOUSES ARNEL L. CALIDA and

MARIAN CALPITO-CALIDA,
Petitioners.
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ENTRY OF APPEARANCE WITH
MOTION FOR ADVANCED TESTIMONY

COMES NOW the petitioner, through the undersigned counsel, in the

above-entitled case unto the Most Honorable Court, most respectfully avers
that:
1. The herein petitioner is presently working and staying in Canada;

2. In relation to her overseas employment, she cannot obtain a vacation

in the Philippines this 2017 for the presentation of her testimony
later than March 31, 2017;

3. That the pre-trial of the case is set on March 28, 2017;

4. Hence, it would be difficult for her to be presented after the pretrial

because of the afore-stated predicament;

5. She could get a vacation from last week of February to first week of
March, 2017.

6. That the petitioner’s testimony is indispensable and an advance

testimony shall promote the speedier disposition of the above-
entitled case, without prejudicing the established rules of procedure;

WHEREFORE, in view of the foregoing, it is hereby prayed and moved

that the presentation of the advance testimony of the petitioner be set on
February 28 or March 7, 2017.
All other reliefs, just and equitable, are likewise prayed for.

January 24, 2017, Davila, Pasuquin, Ilocos Norte, Philippines.

 BRIAN JAY CORPUZ
Counsel for the Petitioner
SC Roll No. 61512/03.28.2012
PTR No. 1389556/01.04.17/Ilocos Norte
IBP Lifetime No. 938257/Ilocos Norte
MCLE Compliance No. V -0005261/
January 8, 2015
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The Clerk of Court
RTC-Branch 19
Bangui, Ilocos Norte

GREETINGS:

Please take notice that the undersigned counsel will submit the foregoing Motion
immediately upon receipt hereof for the kind consideration and approval of the Most
Honorable Court.

BRIAN JAY CORPUZ

Counsel for the Petitioner

Furnished by personal service:

Office of the Provincial Prosecutor

Marcos Hall of Justice, Laoag City