Republic of the Philippines

REGIONAL TRIAL COURT

11th Judicial Region
Branch 34, Davao City

BAR BEE
Plaintiff,

Civil Case No. 22222

- versus - For: Collection of Sum of
Money

ELL SAH
Defendant.
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MOTION FOR POSTPONEMENT

Plaintiff, by and through counsel, and unto this Honorable Court, most
respectfully states that:

1. This case is set for trial on March 2, 2020 at 8:30 in the morning;

2. On said date and time, the undersigned counsel will be unable to

appear before this Honorable Court as he has also been directed to
appear on said date and time before the Branch 34 of RTC 11 at
Panabo City for People of the Philippines v. Liba Kera, Criminal
Case No. 11-1111, where he is scheduled to terminate cross-
examination of the prosecutor’s expert witness who will be
available only on said date and time;

3. Without impugning the importance of these proceedings, plaintiff

respectfully submits that his attendance in the criminal case
becomes indispensable; otherwise, the accused in said case would
be deprived of the opportunity to confront and cross-examine a
vital witness against him;

4. This motion is prompted only by the foregoing reason and not for
delay;

WHEREFORE, it is respectfully prayed that the hearing set on

March 2, 2020 be reset to another day preferably on March 16, 2020
or at the convenience of this Honorable Court.

Davao City, Philippines, February 27, 2020.

 DAVE BEE
Counsel for Plaintiff
Attorney’s Roll No. 10772
PTR No. 7862245 B; 01-02-20; Davao City
IBP O.R. No. 024454; 01-02-20; Davao City
Door 1, VMJ Bldg, Buhangin, Davao City
Tel. No. 218-3595

NOTICE OF HEARING

To:
ATTY. JESS SY
Counsel for the Defendant
Door 5, YG Bldg., Sala St.
Panabo City

GREETINGS!

Please take notice that on Monday, March 16, 2020 at 8:00am., or as

soon thereafter as counsel may be heard, the undersigned will ask this
Honorable Court to approve the foregoing Motion for Postponement.

ATTY. DAVE BEE

Counsel for Plaintiff