Sample Motion to Resolve Motion for Execution

Republic of the Philippines MUNICIPAL TRIAL COURT IN CITIES Lapulapu City GENERAL MILLING CORPORATION, Plaintiff , CIVIL CASE No. M-LLP-10-01201-CV -versusFOR: EJECTMENT ROMA ZOILA, Defendant. X-----------------------------------------------------/

MOTION TO RESOLVE MOTION FOR EXECUTION

PLAINTIFF, through the undersigned counsel, unto this Honorable Court most respectfully moves for the resolution of the Motion for Execution of the judgment of the herein case dated March 26, 2012 and hereby states, THAT:

1. A Motion for Execution of the judgment of the herein case dated March 26, 2012 was filed before this Honorable Court on March 21, 2013 by the undersigned; 2. Until now, there is no resolution to that motion. PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this Honorable Court to issue a WRIT OF EXECUTION of the aforesaid judgment, for it to be properly executed and enforced. Other just and equitable remedies under the circumstances are likewise prayed for. March 30, 2015, City of Cebu (for Lapulapu City), Philippines. RESPECTFULLY SUBMITTED.

LOON CORPUZ AND ASSOCIATES (Counsel of Plaintiff) G/F GMC Plaza Bldg. Legaspi Extension corner M.J Cuenco St, Cebu City, Philippines Tel No. (032) 254-0453; Cel No. 09985538170 By: VALERIANO S. LOON Roll of Attorney No. 50071 IBP OR No. 15641; January 7, 2014; Cebu City PTR OR No. 405128; January 7, 2014, Cebu City Email add: [email protected] MCLE COMPLIANCE No. IV-0033617; December 2, 2011

The Clerk of Court MTCC- Lapulapu City Madam: Please submit the foregoing motion for hearing on April 17, 2015 at 9:00 o’clock in the morning for the consideration and resolution of the Honorable Court.

VALERIANO S. LOON Roma Zoila Lot 14, near SPIRLA Chapel Dimataga St., Poblacion, Lapu-lapu City Dear Madam: Please take notice that the foregoing motion will be submitted for hearing on April 17, 2015 at 9:00 in the morning for the consideration and resolution of the Honorable Court.

EXPLANATION

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Copy of this motion was furnished to the herein counsel of the defendant through registered mail because personal service is impractical due to distance and lack of personnel to do the same. VALERIANO S. LOON

Copy furnished:

Roma Zoila Lot 14, near SPIRLA Chapel Dimataga St., Poblacion, Lapu-lapu City

EXPLANATION Copy of this motion was furnished to the herein defendant and his counsel through registered mail because personal service could not be done due to distance and lack of personnel to do the same.

VALERIANO S. LOON

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