Entry of Appearance With Urgent Motion To Reset Hearing

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Republic of the Philippines

4th Judicial Region


MUNICIPAL TRIAL COURT
Pila, Laguna
Email: mtc2pla000@judiciary.gov.ph
Contact No. 09152319841

PEOPLE OF THE PHILIPPINES,


Plaintiff,

Criminal Case No. 4687-4690


-versus- For: Violation of BP 22 (4 counts)

ELLA MAY PRADO,


Accused.
x-----------------------------------------------x

ENTRY OF APPEARANCE WITH


URGENT MOTION TO RESET HEARING

NOW COMES the accused in the above-entitled case, by her


undersigned counsel, and to this Honorable Court, most respectfully
moves to cancel the hearing scheduled on November 8, 2023 at 1:30
o’clock in the morning on the following grounds:

1. The undersigned counsel has just been recently engaged for this
case as counsel for the accused and has another pre-scheduled
hearing in an equally important case entitled “PEOPLE OF THE
PHILIPPINES vs. ESPERANZA APRUEBO”, docketed as CRIM. CASE
NOS. 22-077 to 22-080 and pending with the Municipal Trial Court of
Caloocan City, Branch 86.

2. With this, the undersigned is constrained to respectfully request


the Honorable Court to reset the hearing of the instant case to
another date subject to the availability of the Honorable Court’s
calendar, preferably on January 10 or January 17, 2024 at 1:30
o’clock in the morning.

3. This Motion is not intended to delay the early resolution of this case
but is genuinely prompted by the foregoing circumstances.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of


the Honorable Court that:

1. The hearing scheduled on November 8, 2023 at 1:30 o’clock in


the morning be reset to another date subject to the availability of
the Honorable Court’s calendar, preferably on January 10 or
January 17, 2024 at 1:30 o’clock in the morning.
2. Note the appearance of the undersigned as counsel for the
accused.

Antipolo City, for Pila, Laguna.

October 31, 2023.

ATTY. NESTOR P. PINLAC


Counsel for the Accused
SALVADO AND CHUA LAW OFFICES.
3/F, No. 42 GSIS Ave., Cogeo Village
Brgy. Bagong Nayon I, Antipolo City
IBP No. 181791 (2023)/4 Jan. 2022/Pang.
PTR No. 5102681/3 Jan. 2023/ Mandaluyong City
MCLE Compliance No. VI- finished 18 November2022
Roll of Attorneys No. 51293
MCLE Compliance No. VII – on-going#0917-8760521
hoodzie_87345@yahoo.com.ph

Conforme:

ELLA MAY PRADO

Copy Furnished:

PROSECUTOR AISSA A. MERCADO


OPP, Sta. Cruz, Laguna

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