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URGENT MOTION TO RESET HEARING - See Tiong Macario

This urgent motion requests to reset the hearing for a criminal estafa case from November 6, 2020 to a later date. The accused's counsel was recently engaged in the case and needs more time to prepare, as the accused is eight months pregnant. Attached medical records show the accused's pregnancy. The motion aims to avoid delaying the case's resolution, but requests the reset due to the legal and equitable circumstances regarding the accused's condition and counsel's need for preparation time during the pandemic.

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jason simbre
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359 views4 pages

URGENT MOTION TO RESET HEARING - See Tiong Macario

This urgent motion requests to reset the hearing for a criminal estafa case from November 6, 2020 to a later date. The accused's counsel was recently engaged in the case and needs more time to prepare, as the accused is eight months pregnant. Attached medical records show the accused's pregnancy. The motion aims to avoid delaying the case's resolution, but requests the reset due to the legal and equitable circumstances regarding the accused's condition and counsel's need for preparation time during the pandemic.

Uploaded by

jason simbre
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOC, PDF, TXT or read online on Scribd
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REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION


METROPOLITAN TRIAL COURT
Branch 47
Pasay City

PEOPLE OF THE PHILIPPINES Criminal Case No. M-PSY-19-


Plaintiff, 03688-CR

-versus- For: ESTAFA through


Falsification of Commercial
KAREN SEE TIONG- MACARIO Document
Accused.
x------------------------------------------------x

URGENT MOTION TO RESET HEARING

COMES NOW, the Accused through undersigned counsel and unto this
Honorable Court, most respectfully moves for a re-setting of the hearing on
the instant case and in support thereof, avers THAT:

1. This instant case is set on 6 November 6, 2020 at 8:30 o’clock in the


morning. The undersigned was just engaged the other day,
November 4, 2020 since there is still an existing pandemic.

2. Please be informed that she is currently eight (8) months pregnant


therefore, it is not advisable and very hard to look for a lawyer to
handle her case due to her current condition and pandemic;

Attached is the Accused’s Congenital Scan and Ultrasound as


“Annex A and A-1”

3. Hence, the undersigned counsel begs the indulgence of the


Honorable Court for the opportunity to obtain all necessary
documents pertaining to the instant case and time to prepare for the
Accused’s defense.

4. In view of this, the undersigned counsel most respectfully asks the


kindness of this Honorable Court to allow the re-setting of the
hearing of this case originally set on 6 November 2020 at 8:30 o’clock
in the morning to the next possible scheduled hearing, or a date most
convenient to this Honorable Court or as deemed proper;

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5. The aforesaid motion is not intended to delay the prompt disposition
of the instant case but is only compelled by the foregoing legal and
equitable consideration.

PRAYER

WHEREFORE, it is most respectfully prayed of this Honorable Court


that the instant Motion be GRANTED and the hearing originally
scheduled on 6 November 2020 at 8:30 o’clock in the morning be
CANCELLED and RESET to the next possible scheduled hearing, or a date
most convenient to this Honorable Court or as deemed proper.

Other reliefs just and equitable under the premises are likewise
prayed for.

Muntinlupa City for Makati City, 6 November, 2020.

By:
ECALNIR and SIMBRE LAW

Unit 1404B Richville Corporate Tower,


Alabang Zapote Road, Madrigal
Business Park
Ayala Alabang, Muntinlupa City
[email protected]

by:

ATTY. MARHEN JASON P. SIMBRE


PTR No. 11889348; 1-2-2020; Las Piñas
IBP No. 089303; 1-2-2020; PPLM
Roll No. 71238
MCLE Compliance No. VI-0010989

Copy furnished:
OFFICE OF THE CITY PROSECUTOR
Pasay City

“ANNEX A”

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ANNEX A-1

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