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Motion To Reset Hearing

This document is a motion filed in the Regional Trial Court of Malolos, Bulacan by attorney Michelle Rivera on behalf of her client Mary Ann Bernardo Clemente. The motion requests to cancel the scheduled hearing on December 10, 2019 at 2:00 pm and reset it to a later date, as the petitioner has obtained a new employment contract in Japan where she resides permanently and will not be able to take vacation leave in time for the scheduled hearing. The motion states it is made in good faith and not intended to delay proceedings. It requests the court to consider the motion immediately upon receipt due to its non-litigious nature and provides an explanation that copies are being served to relevant parties by registered mail due to distance

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944 views3 pages

Motion To Reset Hearing

This document is a motion filed in the Regional Trial Court of Malolos, Bulacan by attorney Michelle Rivera on behalf of her client Mary Ann Bernardo Clemente. The motion requests to cancel the scheduled hearing on December 10, 2019 at 2:00 pm and reset it to a later date, as the petitioner has obtained a new employment contract in Japan where she resides permanently and will not be able to take vacation leave in time for the scheduled hearing. The motion states it is made in good faith and not intended to delay proceedings. It requests the court to consider the motion immediately upon receipt due to its non-litigious nature and provides an explanation that copies are being served to relevant parties by registered mail due to distance

Uploaded by

mitsrivera
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

Third Judicial Region


REGIONAL TRIAL COURT
Malolos, Bulacan
Branch 21

IN THE MATTER OF PETITION FOR


CANCELLATION OF THE
CERTIFICATE OF LIVE BIRTH OF
MARY ANN BERNARDO CLEMENTE
WITH REGISTRY NO. 2811-1071

Petitioner, SPC. Case No. P-174-2018

-versus-

THE CITY CIVIL REGISTRAR


AND ALL PERSONS/ENTITIES
WHO/WHICH MAY BE AFFECTED
THEREBY,

Respondent.
x------------------------------------------------x

MOTION TO RESET HEARING

The PETITIONER, through the undersigned counsel, and unto this


Honorable Court, most respectfully states that:

1. The hearing of this case has been previously set for further
presentation of Petitioner’s evidence on 10 December 2019 at
2:00 pm;

2. However, the Petitioner has just recently obtained a new


employment contract in Japan where she is a permanent resident,
hence, she will not be able to go on a vacation leave yet in time for
the abovementioned hearing;

3. This motion is made in good faith and not intended to delay the
proceedings of this case.
WHEREFORE, it is respectfully prayed that the hearing set on 10
December 2019 at 2:00 PM be cancelled and reset to a later date as of
the availability of the Court Calendar of this Honorable Court.

Other just and equitable reliefs are likewise prayed for.

Respectfully submitted. 25 November 2019. City of Caloocan for


Malolos, Bulacan.

By:

ATTY. MICHELLE C. RIVERA


Counsel for Petitioner
2424 Administration Site Tala, Caloocan City
(02) 990-0609/ 0917-5798026
attymitch.rivera@gmail.com
Roll of Attorneys No. 65874
IBP No. 066264/ 01-09-2019/ Manila IV Chapter
PTR No. 6429160/ 01-09-2019/ Pasay City
MCLE Compliance No. VI – 0007435

Notice of Hearing and


Copy furnished:

SAPP Anna Maria Angela V. Garcia


City Hall of Malolos, IBP Hall, Jacinto St.
Malolos, Bulacan

Local Civil Registrar of Malolos


Malolos City Hall, Jacinto Street,
San Vicente, Malolos, 3000 Bulacan

Office of the General Civil Registrar


3/F VibalBldg Times Street cor. EDSA,
West Triangle, Quezon City

Philippine Statistics Office


PSA Complex, East Ave.,
Diliman, Quezon City
GREETINGS:

Please take notice that considering the non-litigious nature of this


motion, the same will be submitted for the consideration and approval
of this Honorable Court immediately upon receipt hereof.

ATTY. MICHELLE C. RIVERA

EXPLANATION

Copy of this Motion is being served to the parties mentioned by


registered mail in view of distance and impracticability of personal
service.

ATTY. MICHELLE C. RIVERA

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