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REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH 88
QUEZON CITY

NOEL K. SOLIMAN,
Doing business under the
name and style of:
JOCS MAGICAL EVENTS
MANAGEMENT SERVICES,
Plaintiff,

- versus - Civil Case No. R-QZN-16-03414-CV

TELEPERFORMANCE
PHILIPPINES (CRM/FHCS/
TELEPHILIPPINES), INC.,
Defendant.
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URGENT MOTION TO RESET

COMES NOW, the PLAINTIFF, by and through the

Undersigned Counsel and unto this Honorable Court,
respectfully move for a resetting and in support hereof, avers
that:

1. On Sept. 4, 2017, the Undersigned Counsel received

the notice dated August 17, 2017 setting the Preliminary
conferencel of the instant case on Sept. 20, 2017 at 10:00
a.m..

2. Regrettably, as much as Undersigned Counsel is

desirous to appear on said date and time for the scheduled
hearing of the instant case, he could not do so because on
the same date and time, he was already committed to appear
in the case entitled “People of the Philippines V. Sps. Fidel
Dechavez and Leilanie Dechavez” before the Regional Trial
Court, Branch 123, Caloocan City and in the case entitled
SPS. Fidel and Leilanie Dechavez V. Sps. Mario and Bella
Zatarain. before the Regional Trial Court Branch 126, also in
Caloocan City;

3. That the scheduled hearings of the undersigned’s

cases in Caloocan City was set as early as of May 2017 way
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ahead when he received the notice of hearing in the instant

case on Sept. 4, 2017;

4. The due to the foregoing conflict of schedule, the

Undersigned profusely begs the indulgence of the Honorable
Court, as he is constrained to move for the resetting of the
hearing of the instant case from Sept. 20, 2017 at 10:00 to
the same date Sept. 20, 2017 at 2:00 P.M. or on Sept. 26,
2017 at 10:00 A.M. or October 4, 2017 at 10:00A.M.

5. That this motion is not intended to delay nor disrupt

the speedy disposition of the instant case but mainly due to
the reasons above-stated.

P R A Y E R

WHEREFORE, premises considered, it is respectfully

prayed of the Honorable Court that the hearing set on Sept. 20,
2017 at 10:00 be reset preferably on the same date, Sept. 20,
2017 at 2:00 P.M. or on Sept. 26, 2017, 10:0 A.M. or October
4, 2017 at 10:00 A.M.

Other reliefs and remedies just and equitable under the

premises are likewise prayed for.

City of Manila for City of Quezon, Sept. 13, 2017.

ATTY. ROMEO N. BARTOLOME

Counsel for the Plaintiff
Unit 2-C, 2nd Floor, Dahlia Tower
Suntrust Parkview Condominium
No.181 N. Lopez St., Ermita, Manila
IBP No.1006009/1-05-17/Mla.
PTR No. 6003227/1-05-17/Mla.
Roll No. 37717
MCLE Compliance No. V-0003125
July 25, 2014

NOTICE

THE BRANCH CLERK OF COURT

RTC, Branch – 88,Quezon City

ATTY. MICHAEL FELIPE A. MERCADO

SIGUION REYNA, MONTECILLO & ONGSIAKO
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4th & 6th Floors, Citibank Center

8741 Paseo de Roxas, Makati City

Greetings

Please take notice that Undersigned Counsel will submit

the foregoing Motion for the kind consideration and approval of
the Honorable Court, immediately upon receipt hereof.

ATTY. ROMEO N. BARTOLOME

E X P L A N A T I O N

This is to certify as an officer of the court that a copy of

this MOTION was served to the adverse party, not by personal
service but through registered mail by reason of time and lack
of manpower.

ATTY. ROMEO N.
BARTOLOME

Copy Furnished:

ATTY. MICHAEL FELIPE A. MERCADO

SIGUION REYNA, MONTECILLO & ONGSIAKO
4th & 6th Floors, Citibank Center
8741 Paseo de Roxas, Makati City