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Republic of the Philippines


MUNICIPAL CIRCUIT TRIAL COURT
OF VICTORIA-LA PAZ
VICTORIA, TARLAC

DOMINGA CURACHA GAWAT,


Plaintiff,
-versus-

Civil Case No. 1479-15


For:
EJECTMENT

with

DAMAGES
NESTOR LORENZO,
Defendant.
x-------------------------------------------x

ENTRY OF APPEARANCE
(With Motion To Reset Preliminary
Conference)
COMES NOW, the Defendant, through the undersigned
counsel, to this Honorable Court, most respectfully submits
this Entry of Appearance with Motion to Reset Preliminary
Conference and, in support thereof, states that:
1.
It was only today, 11 September 2015, that
defendant sought the assistance of the undersigned as his
counsel in the above-captioned case;
2.
In this regard, the undersigned counsel most
respectfully enters his appearance as counsel for the
defendant;
3.
Hence, it is respectfully requested that the
undersigned be served and furnished
with copies of
pleadings, orders, judgments, and other legal processes
pertinent to this case at Room 206 Jiao Bldg., No. 2 Timog
Avenue, Quezon City;
4.
Likewise, with the kind indulgence of this
Honorable Court, the undersigned is constrained to move for
the resetting of the preliminary conference in this case,
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scheduled on 15 September 2015 at 1:30 in the afternoon,


considering that the undersigned is likewise scheduled to
appear in a previously scheduled mediation conference in
relation to the case entitled Gonzales vs. Serapio et al.,
docketed as Civil Case No. M-QZN-13-04116-CV,
pending before the Metropolitan Trial Court (MTC)
Branch 33 of Quezon City. Hence, it is humbly asked of
this Honorable Court that the preliminary conference in this
case be reset on 06 October 2015 at 1:30 in the afternoon;
5.
This Motion To Reset Preliminary Conference is
not intended to delay the early disposition of this case but is
being advanced for the better interest of justice.
PRAYER
WHEREFORE, premises considered, it is most
respectfully prayed that this entry of appearance be noted
and that all copies of pleadings, orders, judgment and other
legal processes pertinent to this case be sent to the address
of the undersigned above-mentioned.
It is also respectfully prayed that the scheduled
preliminary conference originally scheduled on 15
September at 1:30 p.m. be reset on 06 October 2015,
likewise, at 1:30 in the afternoon.
Such other reliefs just and equitable under the premises
are likewise prayed for.
Quezon City for Victoria, Tarlac, 11 September 2015.

LAWIN
(Legal Advocates for Workers INterest)
Counsel for the Defendant
Room 206, Jiao Building
2 Timog Avenue, Quezon City
Email address: lawin2setufree@yahoo.com
Telefax (02) 373-18-44

ERNESTO R. ARELLANO
PTR No. 0560896; 01-05-15; Q.C.
IBP No. 0981335; 01-05-15; CALMANA
ROLL No. 22660
MCLE No. IV-0017780; 22 April 2013

JASPER C. BALBOA
PTR No. 0595301; 01-06-15; Q.C.
IBP No. 0982982; 01-06-15; MANILA I
ROLL No. 63288
MCLE Compliance until 14 April 2016
Admitted to the Philippine Bar on 07 May 2014

CATHERINE G. DELA CRUZ


PTR No. 0761021; 01-27-15; San Juan
IBP No. 0995253; 02-09-2015; Or. Mindoro
ROLL No. 63694
MCLE COMPLIANCE No. V-0005493; 14 January 2015
With my conformity:

NESTOR G. LORENZO
Defendant

NOTICE OF HEARING
THE HONORABLE BRANCH CLERK OF COURT
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3rd MUNICIPAL CIRCUIT TRIAL COURT


OF VICTORIA-LA PAZ
Victoria, Tarlac
ATTY. KAREN P. CAYETANO
Counsel for the Plaintif
IBP Bldg., San Vicente, Tarlac City
DOMINGA C. GAWAT
Plaintif
Batang-Batang, Victoria, Tarlac

G R E E T I N G S:
Please kindly submit the foregoing Motion To Reset the
Preliminary Conference for the consideration and approval of
the Honorable Court immediately upon receipt thereof.

ERNESTO R. ARELLANO
Copy Furnished: by personal service
ATTY. KAREN P. CAYETANO
Counsel for the Plaintif
IBP Bldg., San Vicente, Tarlac City
DOMINGA C. GAWAT
Plaintif
Batang-Batang, Victoria, Tarlac