Republic of the Philippines

REGIONAL TRIAL COURT

Fourth Judicial Region
Branch 17, Cavite City

CHERRY MARIE ILAGAN-CASTRO

Petitioner,
Civil Case No. N-8989
- versus - For: Declaration of Nullity of
Marriage

EDMON E. CASTRO,
Respondent.
x-----------------------------------------x

MOTION FOR LEAVE TO URGENTLY SET

SCHEDULE TO TAKE DEPOSITION
(OF WITNESS DAISY BERNALES-PRAYCO)

PETITIONER, by counsel, most respectfully moves with leave of

court for the URGENT SETTING of taking the deposition of witness Daisy
Bernales-Prayco and avers the following in support thereof:

1. On March 9, 2020, counsel for petitioner filed an “Urgent

Motion for Leave to Take Deposition of Witness Daisy Bernales-
Prayco” who was about to leave for onboard overseas work as a ship
crew. The schedule for taking of deposition was set on March 16, 2020
but which was unfortunately cancelled/postponed due to the lockdown or
enhanced community quarantine caused by the COVID pandemic.

2. In order not to cause further delay to the proceedings of the

case and considering that witness may be called anytime for onboard
overseas work, petitioner is humbly requesting for the URGENT SETTING
of the deposition hearing of subject witness on JULY 13, 2020 or JULY
20, 2020 at 1:30 in the afternoon, as the calendar of this Court may
allow.

PRAYER

WHEREFORE, in view of the foregoing, it is most respectfully

prayed for that DEPOSITION of WITNESS DAISY BERNALES-PRAYCO be
allowed by this Court to be urgently scheduled on JULY 13, 2020 or
JULY 20, 2020 at 1:30 p.m. as the calendar of this Court may allow.

Other just and equitable reliefs are likewise most respectfully

implored.

1
 IMUS CITY FOR CAVITE CITY, 06 July, 2020.

S.T. DE GUZMAN LAW OFFICE

Counsel for Petitioner
Unit 204 Costa Grande Building,
E. Aguinaldo Highway, Palico I, Imus, Cavite 4103
By:
SUSANA T. DE GUZMAN
IBP No. 070190 01-18-2019 Cavite
PTR No. 1376099 01-08-2020 Imus City
Attorney’s Roll No. 43825
MCLE Compliance No.VI-0014652 11/12/2018
Contact Nos.: 0917-7177626/0908-3497135

NOTICE OF HEARING

THE BRANCH CLERK OF COURT

Regional Trial Court
Branch 17, Cavite City 4100

ASST. PROV’L. PROSECUTOR SALVADOR ARNESTO

Office of the Provincial Prosecutor
Imus, Cavite 4103

G R E E T I N G S:

Due to urgency and the restrictions/limitations posed by the

general community quarantine, please take notice that the undersigned
counsel will submit the foregoing motion for the consideration and
approval of this Honorable Court sans oral arguments.

SUSANA T. DE GUZMAN

COPY FURNISHED (By Personal Service):

ASST. PROV’L. PROSECUTOR SALVADOR ARNESTO

Office of the Provincial Prosecutor
Imus, Cavite 4103

2
COPY FURNISHED (By Registered Mail/Private Courier):

THE BRANCH CLERK OF COURT

Regional Trial Court, Branch 17
Cavite City

EDMON E. CASTRO
Blk. 17, Lot 16, Boston Heights Subdivision
Brgy. Toclong, Kawit, Cavite 4104

EXPLANATION

Service by Registered Mail/private courier to the above party/ies

of the foregoing “Motion to Take Deposition” is resorted to due to
distance and for practical reasons.

SUSANA T. DE GUZMAN