Republic of the Philippines

REGIONAL TRIAL COURT

8th Judicial Region
BRANCH 13
Carigara, Leyte

PEOPLE OF THE PHILIPPINES, CRIM. CASE No. RTC 2010-017-CR

Plaintiff, for:

-versus- QUALIFIED THEFT

LUMBRE TAJO, ET AL.,

Accused.
x- - - - - - - - - - - - - - - - - - - - - - - - x

URGENT MOTION TO TRANSFER HEARING

ACCUSED, through counsel, and most respectfully states: THAT---

1. This case has been set for hearing on January 14, 2013 at 8:30 AM.

2. However, on the same date the undersigned counsel is committed to

appear in Crim. Case No. 2011-09-555, entitled Pp vs. Richard White, et al. for Estafa
before the RTC Br. 9, Tacloban City.

3. Considering the conflict of schedule, the undersigned will be unable to

appear at the scheduled hearing of this case on January 14, 2013 at 8:30 AM.

4. This motion is not entitled for delay, but solely for the reason stated above.

WHEREFORE, it is respectfully prayed that the hearing of this criminal case

scheduled on January 14, 2013 at 8:30 AM be cancelled and transferred to NEXT
AVAILABLE DATE IN THE COURT’S AND COUNSELS’ CALENDAR, preferably on
FEBRUARY 20, 2013.

Other just and equitable relief is also prayed for.

LEO S. GIRON
Counsel for the Accused
253 Avenida Veteranos, Tacloban City
Roll No. 37379
IBP Lifetime No. 00733
PTR No. 7097670; 1-3-12; Tacloban City
MCLE Compliance No. IV-0005511; 4-23-12
 NOTICE OF HEARING

The Clerk of Court

RTC Br. 13, Carigara, Leyte

Greetings:

Please submit the foregoing Motion for the consideration and approval of
this Honorable Court immediately upon receipt hereof sans oral argument.

LEO S. GIRON

NOTICE OF HEARING/
COPY FURNISHED:

HON. DENNIS DON M. SOLIS

Public Prosecutor
Carigara, Leyte

ATTY. CARLOS O. ARGUELLES

Counsel for the Accused
Tacloban City

Greetings:

Please take notice that the foregoing motion shall be submitted for the
consideration and approval of the Honorable Court immediately upon receipt hereof
sans oral argument.

LEO S. GIRON