Entry of Apperance With Motion to Reset Preliminary Conference

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Republic of the Philippines3rd MUNICIPAL CIRCUIT TRIAL COURTOF VICTORIA-LA PAZVICTORIA, TARLAC

DOMINGA CURACHA GAWAT, Plaintiff,

-versus-Civil Case No. 1479-15For: EJECTMENT with DAMAGES

NESTOR LORENZO, Defendant.x-------------------------------------------x

ENTRY OF APPEARANCE(With Motion To Reset Preliminary Conference)

COMES NOW, the Defendant, through the undersigned counsel, to this Honorable Court, most respectfully submits this Entry of Appearance with Motion to Reset Preliminary Conference and, in support thereof, states that:1. It was only today, 11 September 2015, that defendant sought the assistance of the undersigned as his counsel in the above-captioned case;

2.In this regard, the undersigned counsel most respectfully enters his appearance as counsel for the defendant;

3.Hence, it is respectfully requested that the undersigned be served and furnished with copies of pleadings, orders, judgments, and other legal processes pertinent to this case at Room 206 Jiao Bldg., No. 2 Timog Avenue, Quezon City;

4. Likewise, with the kind indulgence of this Honorable Court, the undersigned is constrained to move for the resetting of the preliminary conference in this case, scheduled on 15 September 2015 at 1:30 in the afternoon, considering that the undersigned is likewise scheduled to appear in a previously scheduled mediation conference in relation to the case entitled Gonzales vs. Serapio et al., docketed as Civil Case No. M-QZN-13-04116-CV, pending before the Metropolitan Trial Court (MTC) Branch 33 of Quezon City. Hence, it is humbly asked of this Honorable Court that the preliminary conference in this case be reset on 06 October 2015 at 1:30 in the afternoon;

5.This Motion To Reset Preliminary Conference is not intended to delay the early disposition of this case but is being advanced for the better interest of justice.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed that this entry of appearance be noted and that all copies of pleadings, orders, judgment and other legal processes pertinent to this case be sent to the address of the undersigned above-mentioned.

It is also respectfully prayed that the scheduled preliminary conference originally scheduled on 15 September at 1:30 p.m. be reset on 06 October 2015, likewise, at 1:30 in the afternoon.

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

Quezon City for Victoria, Tarlac, 11 September 2015.

L A W I N(Legal Advocates for Workers INterest)Counsel for the DefendantRoom 206, Jiao Building2 Timog Avenue, Quezon CityEmail address: [email protected] (02) 373-18-44

ERNESTO R. ARELLANOPTR No. 0560896; 01-05-15; Q.C.IBP No. 0981335; 01-05-15; CALMANAROLL No. 22660MCLE No. IV-0017780; 22 April 2013

JASPER C. BALBOAPTR No. 0595301; 01-06-15; Q.C.IBP No. 0982982; 01-06-15; MANILA IROLL No. 63288MCLE Compliance until 14 April 2016Admitted to the Philippine Bar on 07 May 2014

CATHERINE G. DELA CRUZPTR No.0761021; 01-27-15;San JuanIBP No.0995253; 02-09-2015; Or.MindoroROLL No. 63694MCLE COMPLIANCE No. V-0005493; 14 January 2015

With my conformity:

NESTOR G. LORENZODefendant

NOTICE OF HEARING

THE HONORABLE BRANCH CLERK OF COURT3rd MUNICIPAL CIRCUIT TRIAL COURT OF VICTORIA-LA PAZVictoria, Tarlac

ATTY. KAREN P. CAYETANOCounsel for the PlaintiffIBP Bldg., San Vicente, Tarlac City

DOMINGA C. GAWATPlaintiffBatang-Batang, Victoria, Tarlac

G R E E T I N G S:

Please kindly submit the foregoing Motion To Reset the Preliminary Conference for the consideration and approval of the Honorable Court immediately upon receipt thereof.

ERNESTO R. ARELLANO

Copy Furnished: by personal service

ATTY. KAREN P. CAYETANOCounsel for the PlaintiffIBP Bldg., San Vicente, Tarlac City

DOMINGA C. GAWATPlaintiffBatang-Batang, Victoria, Tarlac

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