**CAPTION

MOTION FOR POSTPONEMENT/DEFERMENT HEARING

COMES NOW Defendant, thru undersigned counsel, unto this Honorable Court respectfully states:

1. That the above entitled case is set for [*INITIAL] hearing on July 7, 2000;

2. That counsel for defendant is afflicted with influenza and is now under the medical care of Dr. FLU. A copy of the physician’s certificate under is hereto attached [*REASONS: STILL COLLATING/STUDYING CASE AND ITS EVIDENCE, WITNESS IS UNAVAILABLE ETC].

WHEREFORE, it is respectfully prayed that the hearing set on July 7, 2000 be reset to another day preferably on the first week of August 2000 or at the convenience of this Honorable Court.

Manila, Philippines, July 2, 2000.

Sgd. ATTY. LAA Counsel for the Defendant

(Notice of Hearing)(Proof of Service and Explanation)

Republic of the PhilippinesREGIONAL TRIAL COURT

Fifth Judicial RegionBranch 13, Ligao City

JUAN DELA CRUZ,Plaintiff,

- versus - CIVIL CASE NO. 2402 JUANA DELA CRUZ,

Respondent.x-------------------------------------x

MOTION TO RESET HEARING

COMES NOW, PLAINTIFF, thru Counsel unto this Honorable Court most respectfully alleges:

1. That undersigned Counsel for Plaintiff has conflict of hearing on December 18, 2000 at NLRC Calamba City which was set earlier than this Court’s setting.

2. That this motion is not intended to delay any further proceedings of this case but merely because of the conflict in schedule.

3. That it is hereby requested of this Honorable Court to reset the next hearing to January 18, 2001 at 8:30 o’clock in the morning.

WHEREFORE, it is hereby respectfully prayed of this Honorable Court to grant Motion to Reset Hearing from December 18, 2000 to January 18, 2001.

Quezon City for Ligao City, November 29, 2000.

Sgd. ATTY. LAA Counsel for the Plaintiff

(Notice of Hearing)(Proof of Service and Explanation)

REPUBLIC OF THE PHILIPPINESREGIONAL TRIAL COURT

National Capital Judicial RegionBranch 265, Pasig City

JUN BALDOMERO,Plaintiff,

- versus - CIVIL CASE No. 72987-PSGFor: Annulment and Reconveyance

ANNA SAYSONDefendant.

x------------------------------------x

MOTION FOR EXTENSION OF TIMETO FILE ANSWER/FORMAL ENTRY OF APPEARANCE

COMES NOW Defendant, thru counsel, unto this Honorable Court, respectfully avers that:

1. The services of the undersigned counsel were contracted only today, June 1, 2011 and the filing of an answer to above captioned case will expire on June 10, 2000. However, Defendant is still collating documents and information relative to the John and Jane Does concerned and will need an additional period of at least ten (10) days counted from June 10, 2000 within which to file a responsive answer on behalf of defendant Lydia Cu. [*TEN DAYS IS ACTUAL TOO LONG, BUT COURT WILL EXERCISE DISCRETION]

2. In this regard, undersigned counsel without wanting to delay this case but because of other equally pending cases and for the reasons stated above respectfully requests an additional period of ten (10) days counted from June 10, 2011 within which to file an Answer to the above captioned complaint.

3. At the same time, and for the purposes of brevity/economy, the undersigned wishes to inform this Honorable Court of his entry as counsel for defendant Lydia Cu and prays that he be served with processes of this Honorable Court at the address specified herein below, to wit;

ATTY. RGC(address)

WHEREFORE, premises considered, it is respectfully prayed that the foregoing Motion for Extension of Time and Formal Entry of Appearance of the undersigned counsel be favorably considered.

Quezon City for Pasig City, June 1, 2000.

Sgd. ATTY. RGC Counsel for the Defendant

(Notice of Hearing)(Proof of Service and Explanation)

**CONTENTS OF THE BRIEF WOULD DEPEND ON WHAT HAS BEEN PRESENTED IN THE COMPLAINT AND ANSWER OF THE PARTIES

Republic of the PhilippinesREGIONAL TRIAL COURT

Fifth Judicial RegionBranch 13, Ligao City

MARK TECSON, Plaintiff,

- versus - CIVIL CASE NO. 1567

GREGORIO NIEVES, Respondent.x-------------------------------------x

PRE-TRIAL BRIEF OF THE PLAINTIFF

COMES NOW PLAINTIFF, thru Counsel, unto this Honorable Court most respectfully files this pre-trial brief as follows:

I. PARTIES

Plaintiff is willing to entertain the proposal of the Defendant to amicably settle this case.

II. ADMISSIONS

The identity of Defendant Gregorio Nieves is admitted. The existence of a permanent structure constructed by Defendant on the property of Plaintiff is admitted.

III. STIPULATIONS

The property is declared in the name of Pedro Tecson, married to Corazon Reyes. The Plaintiff inherited the property from his parents; therefore, the possession of Plaintiff began from the possession of their parents passed on to them thru inheritance.

IV. ISSUES

A. Whether or not the property belongs to Plaintiff by inheritance.

B. Whether or not the Defendant is a pretender to the rights of ownership and possession by the Plaintiff.

C. Whether or not Plaintiff is entitled to damages and attorney’s fees.

V. DOCUMENTARY EXHIBITS

1. Special Power of Attorney2. Extra Judicial Settlement of Estate3. Affidavit of Publication4. Estate Tax Return and Receipts5. Tax Declarations6. Death Certificates of Pedro Tecson and Corazon Reyes 7. Birth Certificate of Plaintiff8. Demand Letter9. Affidavits

VI. WITNESSES

A. The Plaintiff

B. Barangay Authorities

C. A long time neighbor

D. More or less 5 witnesses in at least eight (8) settings

VII. TRIAL DATES

As will be mutually agreed upon during the pre-trial conference between the parties

RESPECTFULLY SUBMITTED.

Sgd. ATTY. RGC Counsel for the Plaintiff

(Notice of Hearing)(Proof of Service and Explanation)