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Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES


10th Judicial Region
Malaybalay City

PEOPLE OF THE PHILIPPINES,


Plaintiff,

Criminal Case No. 100

-versusFOR:

THEFT

PEDRO CRUZ,
Accused.
x---------------------------------------------------- /

URGENT MOTION FOR POSTPONEMENT

COMES NOW, the undersigned counsel for the defendant and unto this
Honorable Court, most respectfully manifests:
1.
That a notice of hearing for the above titled case was received by the
undersigned last November 7, 2007 informing the undersigned for the scheduled
hearing on November 21, 2007, 8:30 oclock in the morning. (Machine copy of the
notice duly received by the undersigned is hereto attached and marked as
annexA);
2.
That on November 6, 2007, a day prior to the date when the
abovementioned notice was received, the undersigned counsel also received a
another notice of hearing scheduled on the same date, November 21, 2007, 8:30
oclock in the morning in a case for Theft entitled People of the Philippines vs.
John Doe filed by the City Prosecutor of Valencia City docketed as Criminal Case
No. 001, for which case the undersigned is a counsel for the defendant. (Machine
copy of the notice of hearing duly received by the undersigned is hereto attached
and marked as annex B);
3.
That there is therefore a conflict of schedule for the hearing scheduled
on November 21, 2007, 8:30 oclock in the morning, for the two (2) cases handled
by the undersigned counsel ;
4.
That the undersigned counsel is constrained to appear on the case
cited in paragraph 2 of this motion, the notice of which was received by the
undersigned ahead of the notice of the above titled case, on November 6, 2007.

WHEREFORE, premises considered, it is most respectfully prayed to this


Honorable Court that the scheduled hearing pf the above-entitled Criminal case on
November 21, 2007, 8:30 o clock in the morning be please cancelled and reset to
December 10, 2007 at 10:00 oclock in the morning.
Respectfully prayed for.
Malaybalay City, October 30, 2007
JENNY U. SALE, CPA
Counsel for the Defendant
Zone 4, Kalasungay, Malaybalay City
PTR No. 888888 - January 4, 2007
IBP No. 666666 - January 4, 2007
Roll No. 8080808
TIN 928-274-578

THE CLERK OF COURT


Municipal Trial Court in Cities
10th Judicial Region
Malaybalay City
Greetings:
Kindly submit the foregoing Motion for Postponement to the honorable
Presiding Judge immediately upon receipt hereof for the resolution of the same,
sans oral argument.
JENNY U. SALE, CPA
Notary Public
Zone 4, Kalasungay, Malaybalay City
PTR No. 888888 - January 4, 2007
IBP No. 666666 - January 4, 2007
Roll No. 8080808
TIN 928-274-578
Copy furnished:
ATTY. JAIME GARCI
City Prosecutors Office
Malaybalay City