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    Motion To Amend Pre-Trial - Abc

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    chachi
    This document is a motion filed in a civil case in the 10th Municipal Circuit Trial Court in the Province of Leyte, Philippines. The motion requests to amend the pre-trial order to include additional witnesses and their judicial affidavits for the plaintiffs. Specifically, the motion seeks to include the testimony of Emeterio D. Villanoza Jr. and another witness. The plaintiffs apologize for the late addition but argue it is in the interest of justice. The motion will be heard on June 28, 2019.

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    Motion To Amend Pre-Trial - Abc

    Uploaded by

    chachi
    2K views3 pages
    This document is a motion filed in a civil case in the 10th Municipal Circuit Trial Court in the Province of Leyte, Philippines. The motion requests to amend the pre-trial order to include additional witnesses and their judicial affidavits for the plaintiffs. Specifically, the motion seeks to include the testimony of Emeterio D. Villanoza Jr. and another witness. The plaintiffs apologize for the late addition but argue it is in the interest of justice. The motion will be heard on June 28, 2019.

    Original Description:

    Motion to Amend Pre-Trial Order, Accion Publiciana, Recovery of Possession

    Original Title

    Motion to Amend Pre-Trial.abc

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    This document is a motion filed in a civil case in the 10th Municipal Circuit Trial Court in the Province of Leyte, Philippines. The motion requests to amend the pre-trial order to include additional witnesses and their judicial affidavits for the plaintiffs. Specifically, the motion seeks to include the testimony of Emeterio D. Villanoza Jr. and another witness. The plaintiffs apologize for the late addition but argue it is in the interest of justice. The motion will be heard on June 28, 2019.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    2K views3 pages

    Motion To Amend Pre-Trial - Abc

    Uploaded by

    chachi
    This document is a motion filed in a civil case in the 10th Municipal Circuit Trial Court in the Province of Leyte, Philippines. The motion requests to amend the pre-trial order to include additional witnesses and their judicial affidavits for the plaintiffs. Specifically, the motion seeks to include the testimony of Emeterio D. Villanoza Jr. and another witness. The plaintiffs apologize for the late addition but argue it is in the interest of justice. The motion will be heard on June 28, 2019.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
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    You are on page 1of 3

    REPUBLIC OF THE PHILIPPINES

    Province of Leyte
    10 MUNICIPAL CIRCUIT TRIAL COURT
    th

    Isabel-Merida Circuit
    Isabel, Leyte

    HEIRS OF __________,
    namely, ______________ Civil Case No._____

    Plaintiffs,

    -versus- For: Recovery of


    Possession (Accion
    HEIRS OF _____ Publiciana) With Damages,
    Preliminary Injunction and
    Defendants. with Prayer for the
    x-------------------------------x Issuance of a Temporary
    Restraining Order

    MOTION TO AMEND PRE-TRIAL ORDER

    PLAINTIFFS, through counsel, to this Honorable Court,


    respectfully states:

    1. That the Pre-Trial Conference for the present case was


    conducted on May 21, 2019;

    2. That the Pre-Trial Oder was received by the Plaintiff’s counsel


    on June 19, 2019;

    3. That the Pre-Trial Order states that only __________ are to be


    presented by the plaintiffs as witnesses, and there was no
    judicial affidavit pre-marked or marked as exhibits for the
    plaintiffs;

    4. That, however, in the interest of justice, the plaintiffs pray that


    the Honorable Court amend the Pre-Trial Order to include
    additional witnesses vital to the cause of the plaintiffs, and to
    allow the submission of the judicial affidavit/s of all the
    witness/es, in lieu of their direct testimonies, on the hearing
    date of this motion, if the Court grants the amendment;

    5. That, the following are the persons the plaintiffs pray to be

    1
    included as witnesses to be presented during trial and the
    substance of their testimony, contained in their judicial
    affidavits:

    a. Emeterio D. Villanoza, Jr., Acting Regional Register of


    Deeds, Registry of Deeds of Tacloban City – by way of
    subpoena duces tecum and subpoena duces
    testificandum, to produce the original owner’s duplicate of
    the Certificate of Original Title No. P-84975, and to testify
    on its authenticity, (without Judicial Affidavit);

    b. ______ – to testify on the Sale Transaction which


    transpired in the year 1977 and to identify the Deed of
    Absolute Sale which has been marked as an Exhibit, and
    other documents he signed in favor of Jenna T.
    Fernandez, already pre-marked as exhibits;

    6. That these witnesses were not named during the Pre-Trial


    Conference but are vital for the plaintiffs’ cause;

    7. That the plaintiffs apologize for the late addition of witnesses


    and humbly prays for the Honorable Court’s benevolence and
    grant this motion in the interest of justice;

    8. That this motion is not intended for delay or to prolong the


    proceedings in this case but for reasons already stated above;

    WHEREFORE, premises considered, the plaintiffs through counsel


    pray that the Pre-Trial Order be amended to include the Judicial
    Affidavits of the Witnesses already named in the Order, and to
    include the additional following witnesses and their respective Judicial
    Affidavits to be presented during trial: Emeterio D. Villanoza, Jr.,
    and _____.
    Other reliefs, just and equitable under the premises are also prayed
    for.
    Respectfully submitted.

    May 24, 2019. Isabel, Leyte, Philippines.

    2
    _________________
    Counsel for the Plaintiffs
    PTR NO._____; 01/3/19; Mandaue City
    IBP No.___ Cebu Chapter
    SC Attorney Roll No. ____
    MCLE Certificate of Compliance No. _______
    Berovan Bldg., National Highway, Tabok, Mandaue City
    Tel. _____

    NOTICE OF HEARING

    THE BRANCH CLERK OF COURT


    Municipal Circuit Trial Court
    Merida-Isabel Circuit

    Greetings!

    Please take notice that the undersigned counsel will submit the
    foregoing motion for hearing on June 28, 2019 at 10:00 o’ clock in
    the morning or at any time or date according to the availability of the
    court.

    Thank you.

    _______________

    Copy Furnished: (registered mail/lbc due to distance)


    Atty. _______
    Public Attorney III
    Counsel for the Defendants
    Public Attorney’s Office
    Department of Justice
    Ormoc City District

    Received by:______________________ Date:_____________________

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