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Motion to Reset Hearing

The accused's previous counsel can no longer represent him as he now works for the government. The new defense counsel requests to reset the hearing date in order to have time to review the case and prepare. Specifically, the hearing scheduled for August 6, 2019 needs to be rescheduled to a later date based on the court's availability due to the change in legal representation and need for the new counsel to prepare. The motion is filed in good faith and not intended to delay proceedings.

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Karen De Leon
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223 views2 pages

Motion to Reset Hearing

The accused's previous counsel can no longer represent him as he now works for the government. The new defense counsel requests to reset the hearing date in order to have time to review the case and prepare. Specifically, the hearing scheduled for August 6, 2019 needs to be rescheduled to a later date based on the court's availability due to the change in legal representation and need for the new counsel to prepare. The motion is filed in good faith and not intended to delay proceedings.

Uploaded by

Karen De Leon
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

REGIONAL TRIAL COURT


Second Judicial Region
Branch 02
Tuguegarao City, Cagayan

PEOPLE OF THE PHILIPPINES


CRIMINAL CASE NO. 20297
--versus—

VIRGILIO GAMMAD y SABADO


Accused.

x-----------------------------------------x

VERY URGENT EX-PARTE MOTION


TO RESET HEARING

Accused, through the undersigned counsel, unto this


Honorable Court, respectfully avers that:

1. The above-captioned case is scheduled for hearing on


August 6, 2019 at 8:30 A.M. However, the previous counsel,
Atty. Ferdinand Butay, can no longer appear for the accused
since he is now connected with a government agency.
Consequently, the case was assigned to the undersigned
counsel who is requesting for time to review and prepare for the
case;

2. With this, the undersigned counsel 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;

3. This Motion is made in good faith and is not intended to


delay the proceedings of this case had it not been for the above
circumstance for which the undersigned counsel asks for the
kind indulgence of this Honorable Court and the opposing
counsel.

1
PRAYER

WHEREFORE, premises considered, it is most respectfully


prayed that the hearing of the instant case be reset to another
date, subject to the availability of the Honorable Court’s
calendar.

Other reliefs just and equitable under the foregoing


premises are likewise prayed for.

Quezon City for the City of Tuguegarao. August 5, 2019.

The Law Firm of


CASAUAY COLOMA FRANCISCO ESTRELLADO
& ASSOCIATES
Counsel for Accused
Room 300-C, DELTA Building, West Avenue
Corner Quezon Avenue, Quezon City

By:

KAREN R. DE LEON
IBP OR # 087797, Cagayan Chapter
PTR #9268095, 06/28/2019, Cagayan
Roll of Attorney No. 73752
MCLE Compliance (Exempt New Lawyer 2018 Bar)
Mobile No. 0936-514-7838

Copy furnished:

Provincial Prosecutor’s Office

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