Republic of the Philippines

8TH Judicial Region

REGIONAL TRIAL COURT
Branch __, Tacloban City

xxxxx,
Plaintiffs,

- versus - CIVIL CASE NO.

xxxx
Defendants.
x----------------------------------------------x

URGENT EX-PARTE MOTION TO

RESET HEARING
PLAINTIFFS, by counsel, respectfully alleges that:

1.) On September 18, 2014, undersigned counsel received a

copy of the Order dated August 28, 2014 from the Honorable Court
granting his Motion for the resetting of the hearing. In the said
Order, the Honorable Court scheduled the hearing on November 6,
2014.

2.) However, since the fare of all the airline companies for all
flights going to Tacloban especially those scheduled for the months
of November (the anniversary of the Yolanda devastation),
December, and January 2014 (the visit of Pope Francis) have
increased, it has become financially impossible for the Plaintiff to
book a flight for herself as well as the undersigned, her legal counsel.

3.) The Plaintiff and her undersigned counsel appeal to the

kind understanding of the Honorable Court as Plaintiff whose
house was destroyed by typhoon Yolanda -- is still financially reeling
from the tragedy that struck her family and the people of Tacloban
and other provinces. She and her family have moved to a siblings
house in Laguna because she and her husband are now homeless and
jobless.

4.) This motion is not intended for delay but is anchored on

the foregoing reasons.
 PRAYER

WHEREFORE, in view of the foregoing, it is most respectfully

prayed of this Honorable Court that the hearing set on November 6,
2014 be reset to another date convenient to the calendar of the
Honorable Court, but preferably on February 6, 2014 at 8:30 a.m, after
the Pope of the Catholic Church will have visited Tacloban City.

Makati City for Tacloban City, October 13, 2014.

JIMENO COPE AND DAVID

LAW OFFICES
37th Floor, Rufino Pacific Tower
6784 Ayala Ave. cor. V.A. Rufino St.
Makati City
Tel. Nos. (02) 892-4036 to 38
Fax. No. (02) 817-7578
E-mail: jcd@jimenolaw.com.ph
By:

xxxx

NOTICE OF HEARING AND COPY FURNISHED

THE CLERK OF COURT

REGIONAL TRIAL COURT
Branch 6, Tacloban City
Bulwagan ng Katarungan
Magsaysay Blvd., Tacloban City

ATTY. xx
Counsel for other party

Greetings:

Please take notice that the undersigned counsel will submit the
foregoing Motion for consideration of the Honorable Court on 24
October 2014 at 8:30 am without further oral arguments and with
waiver of appearance.

ATTY.

Urgent Ex-Parte Motion to Reset Hearing

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 EXPLANATION

The filing of this Motion to this Honorable Court and copy

furnished by registered mail was resorted to due to time, distance
and manpower constraints.

ATTY.

Urgent Ex-Parte Motion to Reset Hearing

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