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  • Motion For Leave Leg Forms

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    Lawrence Villamar
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    This document contains a motion filed by defendant Mario Dinglasan, represented by the Perez, Park, Kim Law Office, requesting leave from the court to file a third-party complaint. The motion alleges that under the terms of the contract between plaintiff Michael Romero and defendant, the defendant was allowed to hire a substitute. The defendant hired Winley Joy Supnet, who acted negligently and caused the defendant to be held liable. The motion seeks to implead Mr. Supnet as a third-party defendant to prevent multiplicity of suits.

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    Motion for Leave Leg Forms

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    This document contains a motion filed by defendant Mario Dinglasan, represented by the Perez, Park, Kim Law Office, requesting leave from the court to file a third-party complaint. The motion alleges that under the terms of the contract between plaintiff Michael Romero and defendant, the defendant was allowed to hire a substitute. The defendant hired Winley Joy Supnet, who acted negligently and caused the defendant to be held liable. The motion seeks to implead Mr. Supnet as a third-party defendant to prevent multiplicity of suits.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as DOCX, PDF, TXT or read online from Scribd
    Flag for inappropriate content
    96 views3 pages

    Motion For Leave Leg Forms

    Uploaded by

    Lawrence Villamar
    This document contains a motion filed by defendant Mario Dinglasan, represented by the Perez, Park, Kim Law Office, requesting leave from the court to file a third-party complaint. The motion alleges that under the terms of the contract between plaintiff Michael Romero and defendant, the defendant was allowed to hire a substitute. The defendant hired Winley Joy Supnet, who acted negligently and caused the defendant to be held liable. The motion seeks to implead Mr. Supnet as a third-party defendant to prevent multiplicity of suits.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as DOCX, PDF, TXT or read online from Scribd
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    of 3

    PARK, KIM, PEREZ LAW FIRM Unit 8D, Madison Place, Cubao, Quezon City Contact Number: 419-37-28

    Perez.kbiancaetal@gmail.com By: Atty. Katerina Bianca C. Perez Roll No. 385769 IBP No. 874986/02-14-2012/Quezon City PTR No. 95857639/01-15-2013/Quezon City MCLE: April 22, 2013

    REPUBLIC OF THE PHILIPPINES NATIONAL CAPITAL JUDICIAL REGION METROPOLITAN TRIAL COURT, BRANCH 12 QUEZON CITY

    MICHAEL ROMERO, Plaintiff -versusMARIO DINGLASAN, Defendant

    ) ) ) ) ) ) ) )

    Case No. 5501 MOTION FOR LEAVE TO FILE THIRD PARTY COMPLAINT

    DEFENDANT, Mario Dinglasan, by counsel and to this Honorable Court, respectfully alleges: 1. Defendant has been sued on the basis of the multiple causes of action (Annex A of Complaint), which he and the Plaintiff entered in to a Contract of Consignment. Proviso of the Contract states that the Consignee-herein-Defendant was allowed to contract and employ a substitute/sub-agent by the Consignor-herein-Plaintiff. 2. Consignee-herein-Defendant contracted a certain Winley Joy Supnet to act and perform as a sub-agent. As such, the Consignee-hereindefendant is held liable due to the gross negligence of Mr. Supnet. 3. Winley Joy Supnet is of legal age, single, and is a resident of 180 Fitness First Street, Diliman, Quezon, Metro Manila.

    4. Impleading Winley Joy Supnet would not delay the disposition of the case, and would in fact prevent multiplicity of suits. 5. The proposed third party complaint is attached hereto as Annex B. WHEREFORE, defendant prays that he be given leave of court to file the attached third-party complaint, and for such other reliefs as may be just and equitable in the premises.

    Quezon City, August 19, 2013.

    PEREZ, PARK, KIM LAW OFFICE Counsel for Defendant Unit 8D, Madison Place, Cubao, Quezon City Contact Number: 419-37-28 Perez.kbiancaetal@gmail.com

    By:

    ATTY. KATERINA BIANCA C. PEREZ Roll No. 385769 IBP No. 874986/02-14-2012/Quezon City PTR No. 95857639/01-15-2013/Quezon City MCLE: April 22, 2013

    NOTICE OF HEARING

    To: ATTY. CARMI B. DIGNO Counsel for the Plaintiff

    GREETINGS: Please submit the foregoing motion for the consideration and approval of the Honorable Court on August 19, 2013 at 8:30 AM.

    ATTY. KATERINA BIANCA C. PEREZ

    cc: DIGNO-SIBAL LAW OFFICE Counsel for Plaintiff 3rd Floor, 1990 Building, Eastwood City, Quezon City Tel No. 789-2712 digno.sibal.lawoffice@yahoo.com

    EXPLANATION OF SERVICE Copy of the Motion for Leave of Court to file Third-Party Complaint was served to Plaintiffs counsel by registered mail due to time constraint and distance, and for lack of the undersigneds staff who can serve the same in person.

    ATTY. KATERINA BIANCA C. PEREZ

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