FORIO - Entry - Motion For VideoCon or Resetting

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Republic of the Philippines

DEPARTMENT OF EDUCATION
Region III
School Division Office of Bataan

MS. MARIA MAY S. FORIO, Adm. Case No.


Complainant.
DepEd RO-III-2022-05
-versus-

MS. ROBELYN C. HIGUIT For: Neglect of Duty and


Respondents. Misconduct
x-------------------------------------x

ENTRY OF APPEARANCE
WITH
MOTION TO CONDUCT HEARING VIA VIDEO CONFERENCING OR
RESETTING

Complainant, MS. MARIA MAY S. FORIO, through undersigned


counsel, and unto this Honorable Office, most respectfully states that:

By Way of Entry of Appearance

1. The undersigned counsel most respectfully enters her appearance as


counsel for the Complainant. Hence, it is humbly requested that,
henceforth, she be served of all pleadings, orders, decisions,
resolutions, and processes with respect to this case at the address
indicated below.

By Way of Motion to Conduct Hearing via Video Conference or


Resetting of the Formal Investigation on 10 August 2022

2. This case has been set for hearing on 02 August 2022 at 9:00 a.m.;

3. On 31 July 2022, the undersigned counsel tested positive for COVID-


19. A copy of the Rapid Polymerase Chain Reaction Test Result is
attached to form an integral part of this Motion;

4. The recent Guidelines on the Nationwide Implementation of Alert Level


System for Covid-19 Response issued by the Inter-Agency Task Force
for the Management of Emerging Infectious Diseases (IATF) provide for
the updated Quarantine Isolation Protocols for the General Public &
Healthcare Workers and Authorized Sectors (as of 04 June 2022). The
abovementioned guidelines provide for a mandatory quarantine and
isolation for at least seven (7) days for those who obtained a positive
test result from the date the sample was collected;

5. The undersigned counsel respectfully prays to either attend the formal


investigation relative to the above-titled case via video conference, or to
reset the Formal Investigation on 10 August 2022 or on a date most

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convenient for this Honorable Office, as well as to the parties and
counsels involved;

6. The undersigned counsel may receive notices for a potential


videoconferencing through the following email:

atty.arlabantabanzon@gmail.com

7. This Motion is not intended to delay the proceedings of this case, but
solely for the aforementioned purposes and particularly to comply with
the provisions of the IATF rules and regulations.

PRAYER

WHEREFORE, premises considered, it is prayed before this


Honorable Office that the undersigned be made as counsel on record
for the Complainant and her entry of appearance be noted, and most
respectfully moves for this Honorable Office to either allow the
undersigned counsel to attend the hearing set on 02 August 2022 via
videoconference, or reset the said hearing on 10 August 2022 or on
a date most convenient for this Honorable Office, as well as to the
parties and counsels involved.

RESPECTFULLY SUBMITTED.

Other reliefs just and equitable under the premises are likewise
prayed for.

Balanga City, Bataan. 31 July 2022.

FOR:
PAGUIO LAW OFFICE
2nd Flr. SHP Building, J.P. Rizal Street
Balanga City, Bataan

AINAH RAE M. LABANTA-BANZON


Counsel for the Complainant
Roll No. 83973
IBP No. 243037; 06/15/22; Bataan
PTR No. 7969469; 06/21/22; Kalibo, Aklan
MCLE Exempted, pursuant to
MLCE Governing Board Order No. 1, s.2008
M: 0917-524-1129
E: atty.arlabantabanzon@gmail.com
paguiolawoffice@yahoo.com

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