REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT OF MISAMIS ORIENTAL

10TH JUDICIAL REGION
BRANCH 21
LIGAO CITY

SANDARA PARK Civil Case No.19-00340-

Plaintiff, CV

-versus-

YG ENTERTAINMENT rep. by For: DAMAGES WITH

JENNIE KIM, PRAYER FOR
TEMPORARY
Defendant. RESTRAINING ORDER OR
STATUS QUO ANTE
ORDER AND WRIT OF
PRELIMINARY
INJUNCTION

x-----------------------------------------------/

MOTION FOR LEAVE OF COURT TO ADMIT AMENDED

COMPLAINT

The plaintiff, by counsel, respectfully state:

1. On January 28, 2022, the Plaintiff filed a Complaint for

Damages with Prayer For Temporary Restraining Order Or
Status Quo Ante Order And Writ Of Preliminary Injunction
dated January 22, 2021. The Prayer for issuance of Writ of
Preliminary Injunction was denied by the Court.

2. Thereafter, on May 22, 2022, the Defendant filed its Answer

with Counterclaim.

3. After the filing of the Complaint, the Plaintiff incurred

additional losses due to the Defendant’s wanton termination
of the Plaintiff’s processing operations within the Defendant’s
premises, and continued prevention of access to the
 equipment of the Plaintiff which are stored in the premises of
the Defendant.

4. IN THE HIGHER INTEREST OF SUBSTANTIAL JUSTICE AND FAIR

PLAY, and to secure a just, speedy and inexpensive disposition
of the action, there is a great need for the plaintiff to AMEND,
MODIFY, CLARIFY, IMPROVE, AND STRENGTHEN the said
Complaint.

5. Amendments are allowed under Rule 10 of the Rules of

Court, which provides:
Section 1. Amendments in general. - Pleadings may be
amended by adding or striking out an allegation or the
name of any party, or by correcting a mistake in the
name of a party or a mistaken or inadequate allegation
or description in any other respect, so that the actual
merits of the controversy may speedily be determined,
without regard to technicalities, and in the most
expeditious and inexpensive manner.

XXX

Section 3. Amendments by leave of court. - Except as

provided in the next preceding section, substantial
amendments may be made only upon leave of court.
But such leave may be refused if it appears to the court
that the motion was made with intent to delay. Orders
of the court upon the matters provided in this section
shall be made upon motion filed in court, and after
notice to the adverse party, and an opportunity to be
heard.

6. This Motion is does not intend to delay this case, nor introduce
a new cause of action nor alter the theory of the case; its
purpose is to strengthen the complaint in order that the best
interests of justice and fair play may be served and so the
laudable objective of the rules may be promoted.

7. It should be noted that the case has yet to undergo the

Mediation Phase, Pretrial Phase, and Judicial Dispute
Resolution Phase.
7.1 It has not yet reached the Main Trial on the Merits
Phase.

8. The rights of the Defendant and will not be prejudiced by

this fair and reasonable Motion.
WHEREFORE, in the higher interest of justice and for the legal and
factual reasons cited hereinabove, it is respectfully prayed that,
after notice and hearing, an Order be issued admitting the attached
Amended Complaint.

Plaintiff respectfully prays for such and other reliefs as may be

deemed just and equitable in the premises.

29 July 2022. Ligao City, Philippines.

ATTY. JOSHUA L. TUAZON

The Law Office of Atty. Joshua L. Tuazon
414 Hayes St., corner Quirino St.,
Tomolin, Ligao City 9000
Tel. no. (088)3232497; Mobile 0917-7060669
Email: leni.go.law@gmail.com
PTR no. 3025782; 9 December 2015
IBP Lifetime no. 07546
Roll no. 54949
Admitted to the Bar 4/30/08
MCLE Compliance no. III – 0005340; 10/16/2009
MCLE Compliance no. IV – 002839; 10/3/2011
MCLE Compliance no. V – 0000812; 10/29/2013

ATTY. CINDY T. JOSHI

PTR No. 4333420 7/23/19
IBP No. 085006, 7/10/19
TIN No. 445-651-816
Roll No. 72618
Admitted to the Bar on 6/17/19
MCLE Exempt - New Lawyer
 NOTICE OF HEARING

THE CLERK OF COURT

Regional Trial Court
10th Judicial Region
Branch 21
Ligao City

Greetings: Please be informed that the notice of hearing is set 2

August 2022 (Friday) at 2 P.M., for the Honorable Court’s favorable
consideration and approval.

The Clerk of Court is requested to set the hearing on the said date.
Thank you.

Atty. Joshua L. Tuazon Atty. Cindy T. Joshi

Copy furnished:

ATTY. JENNIE KIM

Counsel for Defendant
Press Club Building, Velez Street, Received by: ____________
Ligao City Date Received: __________
(Across Tribute to the Slain Members
of the Press Monument)