Mr - Damages
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Transcript of Mr - Damages
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REPUBLIC OF THE PHILIPPINES
REGIONAL TRIAL COURT OF ILOILO CITY
6th
JUDICIAL REGION
Branch 10
JOKO LOKO Civil Case no. 52122
Plaintiff, For: Damages
-versus
LUKE KULE
Defendant,
x-----------------------------x
MOTION FOR RECONSIDERATION
COMES NOW, plaintiff, through the undersigned counsel, most respectfully avers that:
1) Plaintiff, through counsel, received on February 13, 2013 an Order dated February11, 2013 from this Honorable Court declaring the plaintiff in default. The 15-day period to file a
Motion for Reconsideration to the said order ended on February 25, 2013. However, since
February 25, 2013 fell on a legal holiday, the said Motion for Reconsideration may be filed
today. Hence, the said Motion for Reconsideration is deemed filed within the reglementary
period;
2) With all due respect to the Honorable Court, plaintiff would like to seekreconsideration of its Order dated February 11, 2013;
3) Notwithstanding the said order, plaintiff does not intend to waiver fromprosecuting the above-entitled case, considering that such is a meritorious case and he is within
his rights in filing the same. Unfortunately, though the plaintiff received a copy of the notice of
pre-trial, his counsel was not given a separate copy thereof;
4) In the interest of justice, the reconsideration of the Order dated February 11, 2013of this Honorable Court is in order.
WHEREFORE, plaintiff most respectfully prays of this Honorable Court that the Order
dismissing the case without prejudice dated February 11, 2013 be reconsidered and set aside in
the interest of justice.
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RESPECTFULLY SUBMITTED.
Iloilo City, Philippines, February 26, 2013.
Counsel for the Plaintiff
THE BRANCH CLERK OF COURT
Regional Trial Court
Branch 10, Iloilo City
Greetings:
Please submit the foregoing motion for the consideration and approval of the Honorable
Court on March 15, 2013, Friday, at 8:30 oclock in the morning, without oral argument.
-N O T I C E-
Counsel for the Defendant
Greetings:
Please take note that undersigned counsel will submit the foregoing motion for the
consideration and approval of the Honorable on March 15, 2013, Friday, at 8:30 oclock in the
morning, without oral argument.
Copy furnished by personal service to:
Counsel for the Defendant
Received by: __________________
Date: ________________________
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Explanation
Pursuant to Section 13, Rule 13, Rules of Court, service of the foregoing motion to theCounsel of the defendant is by personal service as evidenced by the official return/proof of
service of the server.