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PRAYER
WHEREFORE, premises considered, it is respectfully prayed of this Honorable Court to
set aside the Order of default.
Other just and equitable remedies are likewise prayed for.
Respectfully submitted on December 5, 2014, in the City of Cagayan de Oro.
BARBA & ASSOCIATES LAW OFFICE
Makati Shangri-La, Metro Manila
+021234567
By:
NOTICE OF HEARING
Clerk of Court
RTC BR230, Quezon City
Atty. XXX
Counsel for Plaintiff
G/F Trinidad Bldg., Yacapin St., Cagayan de Oro City
Greetings:
Please submit the foregoing for the consideration and approval of this Honorable Court at
the soonest possible date at 8:30 in the morning.
The foregoing Motion is being served and filed thru registered mail
with registry receipt and return card, personal service thereof not being
practicable due to distance, time constraint and lack of personnel to go to
Cagayan de Oro City to serve and file this Motion. A copy was also sent
by private courier to ensure timely receipt by the plaintiffs counsel in time
for the hearing set on the notice.
OLIVE ADRIENNE G. BARBA