Republic of the Philippines

National Capital Judicial Region

METROPOLITAN TRIAL COURT
Branch 62, Makati City

STRONGHOLD INSURANCE CO, INC.,
Plaintiff,
Civil Case No. 97237
Versus

PLANTERS PRODUCTS, INC.
EDM BARGE & EQUIPMENT SERVICE,
Defendants.
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MANIFESTATION AND EXPLANATION WITH
WITHDRAWAL OF APPEARANCE AS COUNSEL FOR PLAINTIFF

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COMES NOW, undersigned law firm, unto this Honorable Court, most
respectfully alleges that:

1. On November 22, 2013, it received a copy of the Honorable Courts order,
requiring the undersigned counsel to explain for his failure to appear on
the scheduled hearing last September 10, 2013.

2. In this regard, the undersigned most respectfully manifests unto this
Honorable Court that due to the continued lack of cooperation on the part
of the herein plaintiff in pursuing the case, the undersigned was
constrained to withdraw its appearance and representation for the plaintiff.

3. Hence, case folders were already turned over to the plaintiff last
September 18, 2013, with corresponding motion to withdraw and a letter
addressed to the latter informing them of the undersigneds withdrawal. A
copy of the said letter with stamp receipt by the plaintiff is hereto attached
as Annex A.


4. Thus, undersigned sincerely apologizes for this predicament, and most
respectfully prays unto this Honorable Court to allow it to withdraw as
counsel for the plaintiff.


WHEREFORE, premises considered, it is respectfully prayed unto this
Honorable Court to accept the undersigneds sincerest apologies, and to
allow it to withdraw as counsel for the plaintiff, and that all orders, and
process by this Honorable Court be sent and directed to the plaintiff.

Makati City, Philippines, November 22, 2013.


TAGAYUNA PANOPIO
and ESCOBER LAWFIRM
2
nd
Flr. AZPHI Bldg., cor.
Ma. Aurora and E. Zobel Sts.,
Poblacion, Makati City

By:
JOEY V. HERRERA
Roll No. 61575
PTR No. 3188284/01.25.13/Pasay
IBP No. 919817/1.25.13/PPLM
MCLE Compliance No. IV-0017718


NOTICE OF HEARING

The Branch Clerk of Court
MTC 62 Makati City

Please submit the foregoing pleading/motion immediately upon
receipt thereof by the Court.

ATTY. JOEY V. HERRERA
Atty. Dalmacio Magbuo
Counsel for EDM Barge

Atty. Aristeo San Agustin
Counsel for Planters

Please take note that the foregoing motion/pleading will be
submitted by the undersigned for resolution immediately upon receipt thereof
by the Court.


ATTY. JOEY V. HERRERA
Copy furnished:

Atty. Dalmacio Magbuo
Suite 910 West Wing, PSE Bldg.
Exchage Road, Ortigas Ctr. Pasig

Atty. Aristeo San Agustin
FEMII Annex 2 Bldg., Aduana St.
Intramuros, Manila

EXPLANATION

A copy of the foregoing motion was sent through registered mail
to the other party/ies due to distance and time constraints, and lack of
personnel to effect personal service.

ATTY.JOEY V. HERRERA