Regional Trial Court: Republic of The Philippines 11 Judicial Region Branch 27 Tandag City

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Republic of the Philippines

REGIONAL TRIAL COURT


11th Judicial Region
Branch 27
Tandag City

APOLONIO LOZADA
Plaintiff,
                                  CIVIL CASE No. 1939-18
                               -versus-                      
FOR: “Recovery of Possession, etc.”

H.O GAUDIOSO S. BITCO, ET. AL.


Defendants
x—————————————————-x

UREGENT EX-PARTE
MOTION TO CONDUCT PRE-TRIAL
THRU VIDEOCONFERENCE

COME NOW, the undersigned counsel for Defendants unto this most
Honorable Court , most respectfully states –

1. Last Sunday, undersigned counsel sustained a gaping cut in his foot


when he stepped on sharp object (a steel rod thrown unto the sea
from the nearby road construction) , while swimming in Buenavista,
Agusan del Norte.

2. He is constrained to ask that the Pre-trial Conference of this case


today be conducted thru videoconference as he cannot travel from
Butuan City to Tandag City because of the aforesaid injury.

3. The e-mail addresses of Undersigned counsel and those of his clients


(who are unable to attend the Pre-trial Conference because they
either working/residing in Manila or abroad) are –

a. Undersigned counsel - boboysalise@yahoo.com


b. Defendants-lolitbetco@outlook.de, cerelina_ernst@web.de,
tex_caringal@yahoo.com
4. The rest of the defendants will be personally attend the Pre-trial
Conference.

5. for the This request is submitted in good faith.

Wherefore it is most respectfully prayed of this Most Honorable Court to allow

Most respectfully submitted.

January 25, 2021, Butuan City for Tandag City, Surigao del Sur, Philippines..

THE LAW FIRM OF


SALISE & SULLANO
RGCS Bldg., Narra Road cor. Molave Street
8600 Butuan City
For Defendants
By:

ATTY. ROLANDO G.C. SALISE


Roll No. 48977
MCLE Compliance V-0019414
issued on April 4, 2016
IBP no. (awaiting OR)
PTR No. 2015222 1/4/2021
TIN No. 908-310-719
e-mail add: boboysalise@yahoo.com
Cellphone no. 09485939047

Most respectfully submitted.

November 8, 2021, Butuan City, Philippines.

THE LAW FIRM OF


SALISE & SULLANO
RGCS Bldg., Narra Road cor. Molave Street
8600 Butuan City
For Torreon
By:

ATTY. ROLANDO G.C. SALISE


Roll No. 48977
MCLE Compliance V-0019414 issued on April 4, 2016
IBP no. (awaiting OR) PTR No. 2015222 1/4/2021
TIN No. 908-310-719
e-mail add: boboysalise@yahoo.com
Cellphone no. 09485939047
Notice of Hearing

The Branch Clerk of Court


RTC Branch 3
Butuan City

Hon. Pros. Doreen T. Dejarme


City Prosecutor’s Office
Butuan City

Please take notice that I am submitting the foregoing Motion for consideration of
Honorable Court immediately upon its receipt hereof, or on November 12, 2021 at
2:00 P.M. sans appearance and further argument.

ATTY. ROLANDO G.C. SALISE


For Rosales

CC:

Hon. Pros. Doreen T. Dejarme


City Prosecutor’s Office
Butuan City
(sent electronically )

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