REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

FOURTH JUDICIAL REGION
BRANCH 79 MORONG, RIZAL

ABC CORPORATION,
Plaintiff,

- versus - Civil Case No. 1234

For: EJECTMENT

SPS. JUAN & JUANA DELA CRUZ,

Defendants.
x----------------------------------------------x

MOTION TO WITHDRAW APPEARANCE

COMES NOW the undersigned counsel for the Defendants, unto

this Honorable Court, most respectfully states:

1. That due to professional and personal reasons, undersigned

respectfully requested that he be allowed by this Honorable Court
to withdraw his appearance in this case as counsel for the
Defendants in a Motion to Withdraw Appearance dated 6 January
2017;

2. That for reasons this undersigned counsel has yet to determine,

my former law office forgot to duly file the same, and discovered
only such fact when he was recovering some of his old files at his
former office;

3. That this counsel would like to profusely apologize to the

Honorable Jduge and this court, and state on record that he did
not purposely overlook the filing of the Motion to Withdraw

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 Appearance, nor had any intention in delaying the proceedings of
this honorable court in any way.

4. As such, the undersigned most respectfully requests that he be

allowed to withdraw his appearance in this case as Counsel for the
Defendants. Henceforth, undersigned respectfully prays that
future notices and processes of this Honorable Court and
pleadings, motions, or correspondence from the Plaintiff in this
case be sent directly to the Defendants or to any counsel who may
subsequently enter his appearance for the Defendants.

PRAYER

WHEREFORE, premises considered, undersigned counsel

respectfully prays that he be allowed to withdraw his appearance in the
above-captioned case and that future notices and processes of this
Honorable Court, as well as pleadings, motions or correspondence from
the Plaintiff in this case be sent directly to the Defendants, or to any
counsel who may subsequently enter his appearance for the Defendants,
and that undersigned be relieved of all his responsibilities relative to
this case.

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

Gotham City for Morong, Rizal, 24 July 2018.

PEPE SMITH
420 Mary Jane Street,
Gotham City
IBP No. 000001 / 01.01.2018 / RSM
PTR No. 123456 / 01.01.2018 /Gotham City
Roll of Attorney’s Number 80001

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 MCLE No. V-0013594; 1/26/16
E-mail address: pepethehepe@gmail.com

COPY FURNISHED:

ABC CORPORATION
Plaintiff

ATTY. HARVEY DENT

Counsel for the Plaintiff

SPS. JUAN & JUANA DELA CRUZ

CERTIFICATION/ EXPLANATION ON MODE OF SERVICE

Defendants-Appellants, through the undersigned counsel, hereby

states and manifests that:

1. The service of the foregoing Notice of Appeal upon the

Plaintiff-Appellee and their counsel was made by registered mail, due to
time constraints and the heavy delivery schedule of the firm’s
messengerial personnel.

2. This Certification/ Explanation is being made in compliance

with Section 11, Rule 13 of the 1997 Rules of Civil Procedure.

PEPE SMITH

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