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Motion To Declare Defendant in Default

The plaintiff filed a motion to declare the defendant in default. According to the motion, the defendant was served with the summons and complaint but failed to file an answer within the required period. The plaintiff's counsel is requesting that the court declare the defendant in default and render a judgment as warranted by the complaint. The motion will be set for a hearing.

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Tien Bernabe
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52 views3 pages

Motion To Declare Defendant in Default

The plaintiff filed a motion to declare the defendant in default. According to the motion, the defendant was served with the summons and complaint but failed to file an answer within the required period. The plaintiff's counsel is requesting that the court declare the defendant in default and render a judgment as warranted by the complaint. The motion will be set for a hearing.

Uploaded by

Tien Bernabe
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

Regional Trial Court


Branch 1, Malolos City

Maria M. Dela Cruz


Plaintiff,

-versus- Civil Case No. 20-03

Joseph L. San Pedro


Defendant

MOTION TO DECLARE DEFENDANT IN DEFAULT

Plaintiff, by counsel and unto this Honorable Court,


respectfully states:

1. The records of the Honorable Court show that Defendant


was served with copy of the summons and of the complaint,
together with annexes thereto on _____________;

2.Upon verification however, the records show that


Defendant Joseph L. San Pedro has failed to file his Answer
within the reglementary period specified by the
Rules of Court despite the service of the summons and the
complaint;

3.As such, it is respectfully prayed that Defendant Joseph L.


San Pedro be declared in default pursuant to the
Rules of Court and that the Honorable Court proceed to
render judgment as the complaint may warrant.
PRAYER
WHEREFORE, it is respectfully prayed that Defendant Joseph
L. San Pedro be declared in default pursuant to the Rules
of Court and that the Honorable Court proceed to render
judgment as the complaint may warrant.
Other relief just and equitable are likewise prayed for.
City of Malolos, Bulacan, Philippines, __Date__.
By:

KHRISTIENNE RIAN C. BERNABE


Counsel for Plaintiff
Address: Blk. 20, Lot 07, Rhodonite St.
Rocka Village II, Tabang, Plaridel, Bulacan
IBP NO. 1234510: 01-03-20:Malolos City
PTR No. 9876543: 01-03-20: Malolos City
ROLL OF ATTORNEY No. 510150
MCLE COMPLIANCE No. V-0005101, 01-03-20
NOTICE OF HEARING
HON. CLERK OF COURT
BR. 1

Greetings. 

Kindly bring the foregoing motion to the attention of the


Honorable Court immediately upon receipt thereof and set
the same for hearing on ___ day of ___ 2020, 8:30 A.M.

KHRISTIENNE RIAN C. BERNABE


Counsel for Plaintiff
Address: Blk. 20, Lot 07, Rhodonite St.
Rocka Village II, Tabang, Plaridel, Bulacan
IBP NO. 1234510: 01-03-20:Malolos City
PTR No. 9876543: 01-03-20:Malolos City
ROLL OF ATTORNEY No. 510150
MCLE COMPLIANCE No. V-0005101, 01-03-20

Please be notified that the foregoing motion will be set for


hearing this _____ day of February 2017, 8:30 A.M.

COPY FURNISHED:

KHRISTIENNE RIAN C. BERNABE


Counsel for Plaintiff
Address: Blk. 20, Lot 07, Rhodonite St.
Rocka Village II, Tabang, Plaridel, Bulacan
IBP NO. 1234510: 01-03-20:Malolos City
PTR No. 9876543: 01-03-20: Malolos City
ROLL OF ATTORNEY No. 510150
MCLE COMPLIANCE No. V-0005101, 01-03-20

RECEIVED BY:           

ATTY. Rose F. Bulaklak


Counsel for the Respondent
Guiguinto, Bulacan Philippines

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