REPUBLIC OF THE PHILIPPINES

FOURTH JUDICIAL REGION

REGIONAL TRIAL COURT
TAGAYTAY CITY
BRANCH 133

Plaintiff,

-versus- CIVIL CASE NO. 19

For: Collection of Sum of Money

Defendant.
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URGENT MOTION TO SUSPEND/STAY PROCEEDINGS

COMES NOW the defendant by the undersigned counsel, and unto

this Honorable Court most respectfully states, THAT:

1. This case is set on Pre-Trial on;

2. The defendant filed for Court supervised Rehabilitation;

3. The Honorable Regional Trial of subsequently issued a

commencement order dated ____________, suspending all actions or
proceedings in court or otherwise for enforcement of claims against the
defendant.

4. The initial hearing for the said Petition for Rehabilitation is set
on _____________________ where the plaintiff is one of the creditors and is
encouraged to participate in such proceeding for the enforcement of her
claim;

5. Accordingly, defendant hereby humbly moves this Honorable

Court to suspend the proceedings for the above-captioned case in
accordance with RA 10142 or the Financial Rehabilitation and Insolvency
Act (FRIA) and A.M. No. 12-12-11-SC.

6. This motion is being filed solely for the foregoing purpose and
not in any manner intended to be dilatory.
 IN VIEW OF THE FOREGOING PREMISES, it is most respectfully
prayed of this Honorable Court, that after Notice and Hearing, it issues an
Order granting the foregoing Motion and suspending the proceedings.

Other just and equitable reliefs under the premises are likewise
prayed for.

________________City for Tagaytay City, ________________

Counsel for the Defendant

NOTICE OF HEARING

THE BRANCH CLERK OF COURT

RTC Branch 133, Tagaytay City

Please take notice that the undersigned shall submit the foregoing
Motion for the kind resolution and approval of the Honorable Court
on____________at eight thirty o’clock in the morning (8:30am).

COPY FURNISHED

ATTY.
EXPLANATION
(Pursuant to Section 11, Rule 13 of the 1997 Rules of Civil Procedure)

The foregoing URGENT MOTION TO SUSPEND/STAY

PROCEEDINGS is being served to the Plaintiff by registered mail and
license courier service due to distance and lack of sufficient personnel to
personally serve the same.

MARK ORLINE S. BUENA