Republic of the Philippines

REGIONAL TRIAL COURT

National Capital Region
Branch 34
Makati City

KARRYL GASTON
Plaintiff,

CIV case no. 12345

- versus-

ANNE S. GUINTO,
Defendant.
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MOTION TO POSTPONE HEARING

COMES NOW DEFENDANT, through undersigned counsel, unto this

Honorable Court respectfully states THAT:

1. The date set for the Pre-Trial Conference of this case was on

April 20 2018;

2. However, the undersigned counsel hereby regretfully informs

Honorable Court that he cannot attend said hearing due to

conflict in other co-equally important hearing schedules;

3. With this, the undersigned is constrained to respectfully

request the Honorable Court to reset the hearing of the instant

case to May 21, 2018, subject to the availability of the

Honorable Court’s calendar.

4. This motion is made in good faith and not intended to delay

the proceedings of the instant case.

WHEREFORE, based on the premises presented, it is most

respectfully prayed that the hearing of the instant case be reset to

May 21 2018, subject to the availability of the Honorable Court’s

calendar.

Cebu City, March 24, 2018.

JOSEPH P. GAVIOLA
Counsel for Defendant
PTR No. 0318551
Issued at Cebu City
Issued on 01-24-18
IBP No. 670230
Issued at Cebu City
Issued on 01-24-18
Roll No. 47893
MCLE No. 7899907
 NOTICE OF HEARING

The Clerk of Court

Regional Trial Court Branch 34
Makati City

Greetings:

Kindly submit the foregoing motion for the consideration and

approval of the Honorable Court immediately upon your receipt hereof.

JOSEPH P. GAVIOLA

EXPLANATION

Undersigned Accused has furnished the private prosecutor a copy

of the foregoing motion though registered mail, and not by personal

delivery, because of distance and time constraint.

JOSEPH P. GAVIOLA

COPY FURNISHED by registered mail:

Atty. Joselito Gamboa
Counsel for Plaintiff
7h Floor Tower Building
F. Ortigas Jr. Avenue, Ortigas Center, Pasig City, Metro Manila