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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


NATIONAL CAPITAL JUDICIAL REGION
Branch 230
QUEZON CITY
XXX CORP. INC.,
Plaintiff,
- versus JOHN D. CRUZ,
Defendant.
x - - - - - - - - - - - - - - -x

CIVIL CASE NO. 2014-176


For: Collection of Sum of Money,
Damages, and Attorneys Fees

MOTION FOR RECONSIDERATION


(to Set Aside Order of Default)
PLAINTIFF, through the undersigned counsel, most respectfully states that:
1. Plaintiff was declared to be in default on December 3, 2014 when hhe failed to file
his answer within the reglementary period. Herein attached as Annex "1" is the
said Order.
2. Plaintiff begs for a reconsideration of the said Order for the reason that the counsel
was indisposed during the time summons was served at her office and was out of
the country for official business by orders of the President of the Philippines and
appointment by the Strategic Homeland Intervention, Enforcement and Logistics
Division (S.H.I.E.L.D). The undersigned counsel was tasked to settle numerous
complaints filed against a new member of S.H.I.E.L.D., Wade Wilson, more
commonly known as Deadpool, which complaints have grown to become a global
concern, even affecting our countrys security.
3. In the interest of substantial justice and for the reason earlier stated, defendant begs
the compassion of this Honorable Court fo its kind understanding. Delay in the
proceedings of this case was never intended.

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:

OLIVE ADRIENNE G. BARBA


PTR No. 111
IBP No. 111
Roll No. 111
MCLE Compliance No. 111

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.

OLIVE ADRIENNE G. BARBA

COPY FURNISHED BY REGISTERED MAIL:


ATTY. XXX
Cagayan de Oro City

Reg. Receipt No.:__________


Date: ___________
EXPLANATION

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