REPUBLIC OF THE PHILIPPINES ELEVENTH JUDICIAL REGION REGIONAL TRIAL COURT DAVAO CITY, BRANCH 10 CECILIO G. ABENON, ET AL., - versus - CIVIL CASE NO. 95-45 SHELL OIL COMPANY, ET AL., Spe MOTION TO ATTEND HEARING THROUGH VIDEOCONFERENCE Defendants THE DOW CHEMICAL COMPANY ("Dow") and OCCIDENTAL CHEMICAL CORPORATION ("Occidental"), without prejudice to their position that the present case was dismissed against them with finality, through counsel, respectfully state: 1. On 20 Jamuary 2023, Dow/Occidental received a copy of the Honorable Court's "Notice of Hearing" dated 13 December 2022, setting the hearing on the "Entry of Appearance with Verified Motion for the Payment of Claim for Damages" dated 9 December 2022 ("Verified Motion") filed by Atty. Benjamin T. Etulle, on 16 February 2023 at 2:00 p.m. 2. Dow/Occidental, through the undersigned counsels, intend to attend the hearing. However, duc to logistical and health constraints (c.g., possible transmission of COVID-19 via air travel, since undersigned counsel's offices are in Taguig City), the undersigned counsels are constrained to request that they be allowed to attend the hearing through videoconferencing. The aforesaid circumstances are compelling reasons that justify the resort to videoconferencing, consistent with A.M. No. 20-12-01-8C2 3. Undersigned counsels can participate in the videoconference hearing at the following location and through the following email addresses: ‘ By the Supreme Court in a Resolution dated 7 March 2018 with regard to the 1,712 settied plaintiffs (Le., ‘those whose names ean be found in Annexes A to D of the 1997 Compromise Agreements) and by the ‘Honorable Court in an Order dated 10 February 2017 as against te remaining 106 plaints for their fluro ‘to proseoute their case against Dow/Occidental for 19 years. * AM. No. 20-12-01-8C, Item 1, Sub-item 3 (b) (ix).Danielle Joanna | Bonifacio DanielleJoanna Gaite@quisumbingtorres.com C. Gaite Global City, Taguig 1634 | 4. This motion is not intended to delay the proceedings but is filed solely for the foregoing reasons. PRAYER WHEREFORE, defendants Dow Chemical Company and Occidental Chemical Corporation respectfully pray that the Honorable Court allow undersigned counsels to attend the hearing on 16 February 2023, 2:00 pam., through videoconference. Other reliefs, just and equitable under the premises, are likewise prayed for. Taguig City for Davao City, 3 February 2023. Crescent Park West, Bonifacio Global City Taguig City, Metro Manila Telephone: +632 8819-4700 Facsimile: +632 8816-0080 agtdrpe@quisumbingtorres.com bhava 6 mes ( Roll wor a-Quisu 37177 IBP Lifetime No. 03312; 01/05/04; Makati City PTR No. A-5797073; 01/10/23; Taguig City MCLE Compliance No. VI-0026279; 05/29/19 And by:op LE 5 ‘llega 4 Roll of Autémeys No. 52354 IBP Lifetime No. 06276; 01/09/07; RSM PTR No. A-5797070; 01/10/23; Taguig City MCLE Compliance No. VI-0027695; 04/22/19 Andby: 7 Ae PO banaesate fo DANIELLE JOANNA C. GAITE Roll of Attorneys Nov'75309 / IBP‘No. 177883; 02/10/22; Makati City PTR No. A-5790700; 01/07/23; Taguig City MCLE Compliance No. VII-0014050; 03/30/22 Copy furnished: Atty. Benjamin T. Etulle BY REG, MAIL Etulle & Etulle Law Office Purok 3, New Visayas Panabo, Davao City Atty. Oswaldo A. Macadangdang BY EMAIL/REG. MAIL/COURIER Macadangdang Law Office Ground Floor, Door 2 Perica Tulip Townhouse Davao City Atty. Salvador Bijis BY REG. MAIL R-2, UF Torre Building San Pedro-Anda Streets Davao City Atty. Randolph C, Parcasio BY REG, MAIL Parcasio and Summdad Law Office Lot 4, Block 36, Vincent Ways Avenue ‘Vincent Heights Subdivision Davao City Atty. Alberto C. Magulta BY REG. MAIL Unit 115, Bldg. 5, One Oasis Davao Ecowest Drive Matina Davao City Angara Abello Concepcion BY EMAIL/REG. MAIL/COURIER Regala & CruzACCRALAW Tower 2 Avenue comer 30% Street Crescent Park West, Bonifacio Global City Taguig City Sycip Salazar Hernandez BY EMAIL/REG. MAIL/COURIER & Gatmaitan T* Floor, SSHG Law Centre 105 Paseo de Roxas Makati City Cruz Marcelo & Tefiefrancia BY EMAIL/REG. MAIL/COURIER 9th, 10th, 11th & 12th Floors 11th Avenue comer University Parkway Bonifacio Global City, Taguig City 1634 Castillo Laman Tan Pantaleon & BY EMAIL/REG. MAIL/COURIER ‘San Jose Law Offices The Valero Tower 122 Valero Street Salcedo Village, Makati Explanation under Section 11, Rule 13 Due to distance, number of parties and temporary lack of available messenger personnel, personal filing with the Honorable Court and personal service are not practicable. Thus, this pleading / motion / filing is filed with the Honorable Court by registered mail and served on the other parties by email and/or registered mail and/or courier. i Ase Hi Bolin C.GAITE é