2
REPUBLIC OF THE PHILIPPINES
NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
MAKATI CITY
BRANCH xxName of Plaintiff
Plaintiff,
- versus -
Civil Case No. 15-666
For: REPLEVIN
Jane Doe and
John Doe,
Defendants.
x----------------------------------------------x
MOTION FOR POSTPONEMENT OF HEARING
Plaintiff, through counsel and unto this Honorable Court,
respectfully states that:1. The Pre-trial of this case was set on
August 27, 2015. Due to defendants failure to appear on the said
pre-trial, this Honorable Court ordered the ex parte presentation
of plaintiffs evidence, to be held on September 24, 2015 at 8:30 in
the morning.2. Defendants counsel filed a Motion for
Reconsideration and the same was heard on September 11, 2015. The
undersigned counsel was ordered by this Honorable Court to make an
oral comment and opposition to the said motion. After making the
comment and oppositon, this Honorable Court ordered that the Motion
for Reconsideration is already submitted for resolution and that
the tentative for the pre-trial will be on November 12, 2015 at
8:30 in the morning.3. The undersigned counsel is ready to present
the plaintiffs evidence on September 24, 2015. However, in order to
not pre-empt this Honorable Courts pending resolution to the
abovementioned motion, we are constrained to move for the
postponement of the ex parte presentation of the plaintiffs
evidence.4. Additionally, in the event that this Honorable Court
denies the motion, we also pray that the tentative pre-trial set on
November 12, 2015 at 8:30 in the morning, be the new date for the
ex parte presentation of the plaintiffs evidence.PRAYER
WHEREFORE, Plaintiff prays that the ex parte presentation of
plaintiffs evidence set on September 24, 2015 be cancelled and that
the tentative pre-trial on November 12, 2015, be the new date of
the ex parte presentation of the plaintiffs evidence should this
Honorable Court denies the Motion for Reconsideration submitted by
the defendant.Makati City. September 21, 2015.
LAW OFFICE NAMEAddress of Law OfficeBy:LawyerPTR No.
IBP
MCLE Compliance No. IV
Roll No. NOTIFICATION
THE BRANCH CLERK OF COURTRegional Trial Court, Branch xxxMakati
City
Name of Defendants CounselCounsel for defendantsGreetings:
Please submit the foregoing Motion for Postponement and approval
of the Honorable Court immediately upon receipt hereof. Signed by
youCopy furnished by registered mail:Name of Defendants
CounselCounsel for defendants
Address of CounselEXPLANATION AS TO MODE OF SERVICE
Pursuant to Section 11, Rule 13 of the Rules of Court,
Plaintiff, through undersigned counsel, manifests that copies of
this Motion had been sent to the afore-stated parties by registered
mail, rather than by the preferred mode of personal service, in
view of lack of personnel and material time.
Signed by you
