REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
MAKATI CITY
BRANCH xx
Name 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 NAME

Address of Law Office

By:

Lawyer
PTR No.
IBP
MCLE Compliance No. IV
Roll No.

NOTIFICATION
THE BRANCH CLERK OF COURT
Regional Trial Court, Branch xxx
Makati City
Name of Defendants Counsel
Counsel for defendants
Greetings:
Please submit the foregoing Motion for Postponement and
approval of the Honorable Court immediately upon receipt hereof.
Signed by you
Copy furnished by registered mail:
Name of Defendants Counsel
Counsel for defendants
Address of Counsel
EXPLANATION 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