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Republic of the Philippines

National Capital Judicial Region
REGIONAL TRIAL COURT
___ City
Branch __

Petitioner,
Civil Case No. ___
- versus - For: Declaration of Nullity of Marriage under
Art. 35 (par.1) of the Family Code.
(Those contracted by any of the parties
below eighteen years of age)

Respondent,

x- - - - - - - - - - - - - - - - - - - - - - x

URGENT MOTION
(FOR ADVANCED TAKING OF TESTIMONY)

PETITIONER, through counsel, to this Honorable Court,

respectfully states:

1. The petitioner has arrived the Philippines last April 9, 2016

from Dubai where he works as a sales representative to attend the
pre-trial in this case. He is scheduled to leave again on the first week
of June to resume his work.

2. Petitioners first witness is himself and considering the job

that has been waiting for him for more or less two months already,
he cannot afford to fly back again to testify in the instant case, not to
mention the Visa he will be given in which he will not be able to
return to the Philippines for a year or so. Due to his persistent pleas
to his new employer, he was luckily given only until the first week of
June to finish and settle all his affairs regarding this case, with the
sole condition that he return for work in Dubai during such time.
Otherwise, his employment will be forfeited and consequently, he will
be jobless.

3. The petitioner eagerly wants to cooperate in the progress

of this case and so wants to put in help as much as he can. However,
due to time constraints, the petitioner asks for the Honorable Courts
indulgence to allow him to testify during his stay here. It would cause
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much expense and would result in wasted time if he is already here

but is not able to contribute to the needs of the case.

4. Furthermore, he is the breadwinner in the family and the

only one who takes care of all the needs of his child. Petitioner
cannot afford to lose his job for it is the only hope and source of
income of his family. Thus, the petitioner humbly begs the Honorable
Court to allow the advanced taking of his testimony. He respectfully
requests to be allowed to testify on or before the last week of May,
preferably on May 18, 2016.

PRAYER

WHEREFORE, PREMISES CONSIDERED, it is respectfully prayed

that the instant urgent motion for the advance taking of testimony of
petitioner be granted.

Other reliefs, just and equitable in the premises are likewise

prayed for.

City of Manila for City of ___, April 15, 2016.

__Law OFFICES
Counsel for Petitioner

By:
ATTY.
PTR No.
IBP No.
MCLE Compliance
Roll No.
E-mail:

NOTICE OF HEARING

Branch Clerk of Court

RTC Branch __
____

Greetings:
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Please submit the foregoing urgent motion to the Honorable

Court for its consideration and approval on April __ 2016 at 8:30am.

Copy furnished:

Trial Prosecutor
RTC Branch __
___ City

Office of the Solicitor General

134 Amorsolo St., Legaspi Village,
Makati City

____
Respondent
____

Explanation

Copy of the foregoing pleading, if not personally served, was

served by mail as personal service cannot be practically effected
owing to lack of manpower, time, and distance involved.

Atty. ______