**CAPTION

MOTION FOR POSTPONEMENT/DEFERMENT HEARING

COMES NOW Defendant, thru undersigned counsel, unto this Honorable
Court respectfully states:
1. That the above entitled case is set for [*INITIAL] hearing on July 7,
2000;
2. That counsel for defendant is afflicted with influenza and is now under
the medical care of Dr. FLU. A copy of the physicians certificate under
is hereto attached [*REASONS: STILL COLLATING/STUDYING
CASE AND ITS EVIDENCE, WITNESS IS UNAVAILABLE ETC].
WHEREFORE, it is respectfully prayed that the hearing set on July 7, 2000
be reset to another day preferably on the first week of August 2000 or at the
convenience of this Honorable Court.
Manila, Philippines, July 2, 2000.
Sgd. ATTY. LAA
Counsel for the Defendant
(Notice of Hearing)
(Proof of Service and Explanation)

Republic of the Philippines

REGIONAL TRIAL COURT
Fifth Judicial Region
Branch 13, Ligao City
JUAN DELA CRUZ,
Plaintiff,
- versus JUANA DELA CRUZ,
Respondent.
x-------------------------------------x

CIVIL CASE NO. 2402

MOTION TO RESET HEARING

COMES NOW, PLAINTIFF, thru Counsel unto this Honorable Court most
respectfully alleges:
1. That undersigned Counsel for Plaintiff has conflict of hearing on December
18, 2000 at NLRC Calamba City which was set earlier than this Courts
setting.
2. That this motion is not intended to delay any further proceedings of this case
but merely because of the conflict in schedule.
3. That it is hereby requested of this Honorable Court to reset the next hearing
to January 18, 2001 at 8:30 oclock in the morning.
WHEREFORE, it is hereby respectfully prayed of this Honorable Court to
grant Motion to Reset Hearing from December 18, 2000 to January 18, 2001.
Quezon City for Ligao City, November 29, 2000.
Sgd. ATTY. LAA
Counsel for the Plaintiff
(Notice of Hearing)
(Proof of Service and Explanation)

REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT
National Capital Judicial Region
Branch 265, Pasig City
JUN BALDOMERO,
Plaintiff,
- versus -

CIVIL CASE No. 72987-PSG

For: Annulment and Reconveyance

ANNA SAYSON
Defendant.
x------------------------------------x
MOTION FOR EXTENSION OF TIME
TO FILE ANSWER/FORMAL ENTRY OF APPEARANCE
COMES NOW Defendant, thru counsel, unto this Honorable Court,
respectfully avers that:
1. The services of the undersigned counsel were contracted only today, June 1,
2011 and the filing of an answer to above captioned case will expire on June
10, 2000. However, Defendant is still collating documents and information
relative to the John and Jane Does concerned and will need an additional
period of at least ten (10) days counted from June 10, 2000 within which to
file a responsive answer on behalf of defendant Lydia Cu. [*TEN DAYS IS
ACTUAL TOO LONG, BUT COURT WILL EXERCISE DISCRETION]
2. In this regard, undersigned counsel without wanting to delay this case but
because of other equally pending cases and for the reasons stated above
respectfully requests an additional period of ten (10) days counted from June
10, 2011 within which to file an Answer to the above captioned complaint.
3. At the same time, and for the purposes of brevity/economy, the undersigned
wishes to inform this Honorable Court of his entry as counsel for defendant
Lydia Cu and prays that he be served with processes of this Honorable Court
at the address specified herein below, to wit;
ATTY. RGC
(address)
WHEREFORE, premises considered, it is respectfully prayed that the
foregoing Motion for Extension of Time and Formal Entry of Appearance of the
undersigned counsel be favorably considered.

Quezon City for Pasig City, June 1, 2000.

Sgd. ATTY. RGC
Counsel for the Defendant
(Notice of Hearing)
(Proof of Service and Explanation)

**CONTENTS OF THE BRIEF WOULD DEPEND ON WHAT HAS BEEN

PRESENTED IN THE COMPLAINT AND ANSWER OF THE PARTIES
Republic of the Philippines
REGIONAL TRIAL COURT
Fifth Judicial Region
Branch 13, Ligao City
MARK TECSON,
Plaintiff,
- versus -

CIVIL CASE NO. 1567

GREGORIO NIEVES,
Respondent.
x-------------------------------------x
PRE-TRIAL BRIEF OF THE PLAINTIFF
COMES NOW PLAINTIFF, thru Counsel, unto this Honorable Court most
respectfully files this pre-trial brief as follows:
I.

PARTIES

Plaintiff is willing to entertain the proposal of the Defendant to amicably

settle this case.
II.

ADMISSIONS

The identity of Defendant Gregorio Nieves is admitted. The existence of a

permanent structure constructed by Defendant on the property of Plaintiff is
admitted.
III.

STIPULATIONS

The property is declared in the name of Pedro Tecson, married to Corazon

Reyes. The Plaintiff inherited the property from his parents; therefore, the
possession of Plaintiff began from the possession of their parents passed on to
them thru inheritance.

IV.

ISSUES

A. Whether or not the property belongs to Plaintiff by inheritance.

B. Whether or not the Defendant is a pretender to the rights of ownership and
possession by the Plaintiff.
C. Whether or not Plaintiff is entitled to damages and attorneys fees.
V.
1.
2.
3.
4.
5.
6.
7.
8.
9.

DOCUMENTARY EXHIBITS

Special Power of Attorney

Extra Judicial Settlement of Estate
Affidavit of Publication
Estate Tax Return and Receipts
Tax Declarations
Death Certificates of Pedro Tecson and Corazon Reyes
Birth Certificate of Plaintiff
Demand Letter
Affidavits
VI.

WITNESSES

A. The Plaintiff
B. Barangay Authorities
C. A long time neighbor
D. More or less 5 witnesses in at least eight (8) settings

VII. TRIAL DATES

As will be mutually agreed upon during the pre-trial conference between the
parties
RESPECTFULLY SUBMITTED.
Sgd. ATTY. RGC
Counsel for the Plaintiff
(Notice of Hearing)
(Proof of Service and Explanation)