Republic of The Philippines: Urgent Motion For Postponement

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REPUBLIC OF THE PHILIPPINES


MUNICIPAL CIRCUIT TRIAL COURT
7th Judicial Region
Branch 2, Talisay City, Cebu

PEOPLE OF THE PHILIPPINES


Plaintiff,

CRIM. CASE NO. ____


-versus –

RYAN NOAY
Accused,
x------------------------------------------------/

URGENT MOTION FOR POSTPONEMENT

COMES NOW, THE ACCUSED, through undersigned counsel, most


respectfully and humbly avers:

1) The hearing of this case has been set on June 17, 2021 at 8:30
o’clock morning;
 
2) However, the undersigned counsel hereby regretfully informs
this Honorable Court that he cannot attend said hearing
considering that he is attending the Budget Calling Seminar for
the City of Talisay at Dusit Thani, Lapu-Lapu City, for three
days from June 16-18, 2021;
 
3) With this, the undersigned is constrained to respectfully
request the Honorable Court to reset the hearing of the instant
case to another date and undertake to attend the next hearing
of this case;

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
another date, subject to the availability of the Honorable Court’s
calendar.

Talisay City, Cebu, June 16, 2021.

DAVIDE, SUSUSCO and ASSOCIATES LAW OFFICE


COUNSEL FOR THE ACCUSED
Rm. 306 Diaz Bldg., J. Avila St., Capitol Site, Cebu City
By:
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ATTY. GIOVANNI D. SUSUSCO


Counsel for the Accused
IBP NO. 8852 / 01-17-2020 / CEBU
PTR NO. 503905 / 01-17-2020 / CEBU PROV
Roll of Attorneys No. 53097
Admitted to the Bar on April 26, 2007
MCLE VI-0027317
Email: [email protected]

NOTICE OF HEARING

The Clerk of Court


MCTC Branch 2
Talisay City, Cebu

Sir:
Please submit the foregoing motion for the consideration of the Honorable Court
immediately upon receipt hereof without further oral arguments and presence of
counsels.

ATTY. GIOVANNI D. SUSUSCO

Copy furnished:

Talisay City Prosecutor


Palace of Justice, Talisay City, Cebu

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