Professional Documents
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COMES NOW, the Mortgagors Federico Montilla and Ma. Cristina Montilla by
the undersigned counsel, and unto this Honorable Court, most respectfully avers that:
1. An order dated September 15, 2006 issued by this Honorable was received
subject order specifically states that the pending Motion to deputize sheriff
2. It bears stress that there is another prior motion filed by the mortgagors
Montilla prior to the Motion to Deputize Sheriff and which is directly related
possession was filed before this Honorable Court last August 22, 2006 at
3:10 P.M. which is way ahead of the Motion to Deputize Sheriff only filed in
resolution barely two (2) days after it was filed and without giving the
the same is submitted for resolution or in the alternative, the said motion be
the trial court loses jurisdiction upon the approval of the records on appeal
filed in due time and the expiration of the time to appeal of the other parties.
By reason thereof, any execution in relation to the decision in this case may
Honorable Court to hold in abeyance the pending Motion to Deputize Sheriff pending
the filing of a comment/opposition by the mortgagors in fifteen (15) days not later than
October 10, 2006 or in the alternative, that the said Motion to Deputize Sheriff be
submitted for resolution jointly with the other pending motion to suspend or lift the writ
Such other reliefs and remedies just and equitable under the premises are
NOTICE OF HEARING
Greetings!
Kindly submit the foregoing Motion for the consideration and resolution of this
Honorable Court on September 29, 2006 at 8:30 A.M. or as soon as the court calendar
may allow.
Kindly take notice that the undersigned will submit the foregoing Motion for the
consideration and resolution of this Honorable Court on September 29, 2006 at 8:30
A.M. or as soon as the court calendar may allow.
Copy Furnished: