Republic of the Philippines MUNICIPAL CIRCUIT TRIAL COURT OF VICTORIA-LA PAZ VICTORIA, TARLAC
DOMINGA CURACHA GAWAT, Plaintiff, -versus-
Civil Case No. 1479-15 For: EJECTMENT
DAMAGES NESTOR LORENZO, Defendant. x-------------------------------------------x
ENTRY OF APPEARANCE (With Motion To Reset Preliminary Conference) COMES NOW, the Defendant, through the undersigned counsel, to this Honorable Court, most respectfully submits this Entry of Appearance with Motion to Reset Preliminary Conference and, in support thereof, states that: 1. It was only today, 11 September 2015, that defendant sought the assistance of the undersigned as his counsel in the above-captioned case; 2. In this regard, the undersigned counsel most respectfully enters his appearance as counsel for the defendant; 3. Hence, it is respectfully requested that the undersigned be served and furnished with copies of pleadings, orders, judgments, and other legal processes pertinent to this case at Room 206 Jiao Bldg., No. 2 Timog Avenue, Quezon City; 4. Likewise, with the kind indulgence of this Honorable Court, the undersigned is constrained to move for the resetting of the preliminary conference in this case, 1
scheduled on 15 September 2015 at 1:30 in the afternoon, considering that the undersigned is likewise scheduled to appear in a previously scheduled mediation conference in relation to the case entitled Gonzales vs. Serapio et al., docketed as Civil Case No. M-QZN-13-04116-CV, pending before the Metropolitan Trial Court (MTC) Branch 33 of Quezon City. Hence, it is humbly asked of this Honorable Court that the preliminary conference in this case be reset on 06 October 2015 at 1:30 in the afternoon; 5. This “Motion To Reset Preliminary Conference” is not intended to delay the early disposition of this case but is being advanced for the better interest of justice. PRAYER WHEREFORE, premises considered, it is most respectfully prayed that this entry of appearance be noted and that all copies of pleadings, orders, judgment and other legal processes pertinent to this case be sent to the address of the undersigned above-mentioned. It is also respectfully prayed that the scheduled preliminary conference originally scheduled on 15 September at 1:30 p.m. be reset on 06 October 2015, likewise, at 1:30 in the afternoon. Such other reliefs just and equitable under the premises are likewise prayed for. Quezon City for Victoria, Tarlac, 11 September 2015.
LAWIN (Legal Advocates for Workers’ INterest) Counsel for the Defendant Room 206, Jiao Building 2 Timog Avenue, Quezon City Email address: [email protected]
Telefax (02) 373-18-44
ERNESTO R. ARELLANO PTR No. 0560896; 01-05-15; Q.C. IBP No. 0981335; 01-05-15; CALMANA ROLL No. 22660 MCLE No. IV-0017780; 22 April 2013
JASPER C. BALBOA PTR No. 0595301; 01-06-15; Q.C. IBP No. 0982982; 01-06-15; MANILA I ROLL No. 63288 MCLE Compliance until 14 April 2016 Admitted to the Philippine Bar on 07 May 2014
CATHERINE G. DELA CRUZ PTR No. 0761021; 01-27-15; San Juan IBP No. 0995253; 02-09-2015; Or. Mindoro ROLL No. 63694 MCLE COMPLIANCE No. V-0005493; 14 January 2015 With my conformity:
NESTOR G. LORENZO Defendant
NOTICE OF HEARING THE HONORABLE BRANCH CLERK OF COURT 3
3rd MUNICIPAL CIRCUIT TRIAL COURT OF VICTORIA-LA PAZ Victoria, Tarlac ATTY. KAREN P. CAYETANO Counsel for the Plaintif IBP Bldg., San Vicente, Tarlac City DOMINGA C. GAWAT Plaintif Batang-Batang, Victoria, Tarlac
G R E E T I N G S: Please kindly submit the foregoing Motion To Reset the Preliminary Conference for the consideration and approval of the Honorable Court immediately upon receipt thereof.
ERNESTO R. ARELLANO Copy Furnished: by personal service ATTY. KAREN P. CAYETANO Counsel for the Plaintif IBP Bldg., San Vicente, Tarlac City DOMINGA C. GAWAT Plaintif Batang-Batang, Victoria, Tarlac