REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

THIRD JUDICIAL REGION

Jeph H=Gonzakes
Plaintiff.

-versus- For: Sum of Money

Edwin ramos
Defendant

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Motion For Leave To Admit Amended Pleading

COMES NOW the PLAINTIFF, through the undersigned attorney, and

unto this Honorable Court, respectfully avers:

1. That on _____________, Plaintiff filed before this honorable Court a

Complaint for Collection of Sum of Money;

2. That on ________________, the honorable Court ordered that summons

be served on

3. That the Summons for the DEFENDANT was not served on the address

indicated in the Complaint as the Defendant no longer conducts its

business on the said place;

4. That the plaintiff was able to collect information regarding the possible

location of the Defendant Edwin delos Santos;

 5. That the said location points to the following addresses; “Brgy. San

Lorenzo, Mexico, Pampanga” and “243 Sta. Ines Mabalacat, Pampanga;”

6. That in order to aid the Honorable Court in acquiring jurisdiction over the

DEFENDANT, PLAINTIFF opt to file an amended Complaint containing

the mentioned addresses; Attached in this motion is the copy of the

Amended Complaint;

Wherefore, it is respectfully prayed unto this honorable that:

1. the attached Amended Complaint be admitted;

2. the Summons for the DEFENDANT be served anew on the

addresses as indicated in the Amended Complaint;

San Juan, M.M., Philippines, 18 December 2006

counsel

Notice of Hearing

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Greetings! Please take notice that the aforesaid motion will be submitted
for hearing on December _______,_______, at 8 am.
Copy furnished

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