Republic of the Philippines
Fourth Judicial Region
MUNICIPAL TRIAL COURT IN CITIES
DASMARINAS CITY, CAVITE
PEOPLE OF THE PHILIPPINES,
Plantiff
CRIM.CASE NO. 17-0087
FOR: OTHER DECEITS
(Art.318 of the RPC)
-versus-
JULYSES B. FLORES
Accused.
X------------------------------------X
URGENT MOTION
FOR POSTPONEMENT
DEFENDANT, by counsel, to this Honorable Court respectfully
states that;
1. The above captioned case is set for hearing on 25
September 2017 at 1:00 p.m.;
2, However, on 15 September 2017, undersigned counsel was
belatedly informed of the hearing in the court of El Nido, Palawan for
the case entitled: “CAUAYAN ISLAND RESORT PHILIPPINES, INC.
petitioner versus NIKKA DENISE QUINSAAT., et. al., respondents”, for
DAMAGES WITH APPLICATION FOR TEMPORARY RESTRAINING
ORDER AND WRIT OF PRELIMINARY INJUNCTION with docket no.
209, set on 25 September 2017 at 10:00 a.m., which schedule date of
hearing is not transferable being governed by the rules on Summary
Procedure;
3. Accordingly, undersigned counsel is constrained to move
for the cancellation of the hearing set on 15 September 2017 and to
re-set the same on 02 October 2017 at 1:000 p.m.
4. This Motion is made in good faith, without intent to delay
the early disposition of the case and solely for the reasons stated
above.
WHEREFORE, it is respectfully prayed of the Honorable Court
to cancel the hearing set on 15 September 2017 and to re-set the
same on 02 October 2017 at 1:000 p.m.
Other relief equitable under the premises is likewise prayed for.
Makati City for Dasmarinas City, Cavite. 16 April 2018.
ATTY. REMEGIO C. DAYANDAYAN, JR.
Counsel for Accused
3rd floor, Universal Reinsurance Building
106 Paseo de Roxas, Makati City
PTR #5918218/1.10.17/ Makati City
IBP No. 1053943/12.15.16/ Quezon City
Roll of Attorneys No. 55149
5th Compliance No. 0010757; September 25, 2015
NOTICE
The Branch Clerk of Court
MUNICIPAL TRIAL COURT IN CITIES
Dasmarinas City
Greetings:
Please submit the foregoing motion for approval and consideration
of the Honorable Court immediately upon receipt hereof.
REMEGIO C. DAYANDAYAN, JR.
Copy furnished:
THE BRANCH CLERK OF COURT
MUNICIPAL TRIAL COURT IN CITIES
Dasmarinas City
Dasmarinas City, Cavite
ATTY. ALFEO T. SICCUAN
5-31 Emerald St., Diamond Village
Brgy Salawag. City of Dasmarinas,Cavite
EXPLANATION
The copy of ATTY. ALFEO T. SICCUAN was served through Special
Courier Service on September 21, 2017 and registered mail due to distance,
time constraint and lack of office messengerial personnel
REMEGIO C. DAYANDAYAN, JR.