Вы находитесь на странице: 1из 3

Republic of the Philippines

National Capital Judicial Region


REGIONAL TRIAL COURT
Branch 122, Las Pinas City

PEOPLE OF THE PHILIPPINES


Plaintiff.

- versus - CRIM. CASE NO. 71832-34


FOR: VIOLATION OF B.P. 22

MARILYN S. DELA CRUZ


Accused.
x------------------------------------------------x

VERY URGENT MOTION TO POSTPONE


AND REQUEST TO REPRODUCE RECORDS
WITH FORMAL ENTRY OF APPEARANCE
COMES NOW the undersigned counsel and to this Honorable Court,
most respectfully avers that:

1. The above-entitled cased are scheduled for trial on February


13, 2019 at 1:30 o’clock in the afternoon. Unfortunately, the
service of the undersigned counsel was just recently secured
by the accused as he has in fact have formally entered his
appearance today for these cases;

2. Further, the undersigned is currently attending the 48th Pre-


Judicature Program conducted by the Supreme Court through
PHILJA from February 11 to 22, 2019 at Bayview Park Hotel
Manila. Thus, in the interest of justice and as new counsel for
the accused, it is most respectfully requested that a sufficient
time be given to study the records of this case. For reference,
attached is a letter of admission as ANNEX “A”;

3. Thus, the undersigned likewise respectfully requests a copy of


the records in the instant case in order to prepare for the next
scheduled hearing. This Motion is not intended to delay the
proceedings but solely for the purpose/s alluded thereto;

4. Finally, the undersigned enters his appearance as counsel for


accused, in the above-entitled cases. Henceforth, please cause
the sending of pleadings, notices, motions, orders and other
documents to the undersigned’s address below:

1
ATTY. JAIRUS B. RUBIO
RUBIO LAW OFFICE
3 Floor Joy Nostalg Center,
rd

17 ADB Ave., Ortigas Center,


Pasig City, Metro Manila 1600

PRAYER

WHEREFORE, FOREGOING PREMISES CONSIDERED, it is most


respectfully prayed unto this Honorable Court that this Urgent Motion and
Formal Entry of Appearance as counsel for the accused be NOTED and
APPROVED.

Other just and equitable reliefs are also prayed under the premises.

Pasig City, this 12th day of February 2019

Respectfully submitted.

ATTY. JAIRUS B. RUBIO


Counsel for the Accused
Roll No. 64701
PTR No. 059386; 01/07/19; QC
IBP No. 087453; 01/07/19; QC
MCLE Compliance No. V-0022377

COPY FURNISHED WITH EXPLANATION

THE BRANCH CLERK OF COURT


RTC Branch 122, Las Pinas City

ACP PAUL MICHEAL T. MEJIA


Trial Prosecutor
Office of the City Prosecutor of Las Pinas City
3rd Floor, Hall of Justice Bldg.
Zapote-Alabang Road, Las Pinas City

Greetings!

Since the foregoing URGENT MOTION WITH FORMAL ENTRY


OF APPEARANCE prays for a non-litigious relief, the granting of which

2
shall not prejudice any party, please submit the foregoing for consideration
of the Honorable Court.

ATTY. JAIRUS B. RUBIO


Counsel for the Accused

Похожие интересы