Motion for Leave of Court To Serve Summons by Publication Sample

REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT
City of Manila
Branch 1

JOHN DUMAS,
Plaintiff,

-versus- CIVIL CASE No. 23456

FOR: Recovery of Possession
VAN SHELDON, with Damages
Defendant.

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MOTION FOR LEAVE OF COURT

TO SERVE SUMMONS BY PUBLICATION

COMES NOW, the plaintiff, through the undersigned counsel and unto this Honorable Court,
most respectfully avers:
1. That on August 25, 2012, copy of the summons was served by the process server of this Honorable
Court to the defendant on his given address, but defendant is no longer residing on his given address;
2. That considering that the whereabouts of the defendant is unknown and this case affects the property
of the defendant, plaintiff most respectfully move with leave of court to serve summons by publication.
WHEREFORE, plaintiff prays that the summons be served by publication based on the above
reasons.

Such other relief and remedies as may be deemed just and equitable under the premises are
likewise prayed for.

City of Manila, August 29, 2012.

ARUM AND SYQUIA LAW OFFICE

Counsel for the Plaintiff
Unit 314 The Tower
Taft Avenue, Manila

By:
CHARLES ARUM
Roll No. 45678
IBP No. 23456/1-3-12/Manila
PTR No. 87654/1-3-12/Manila

NOTICE OF HEARING

VAN SHELDON
Defendant

GREETINGS:
 Please submit the foregoing motion for the consideration and approval of the Honorable Court
on September 9, 2012 at 2:00 PM.

CHARLES ARUM

Copy furnished:
VAN SHELDON
345 Nakpil Street
Manila

EXPLANATION

Copy of the Motion to Serve Summons by Publication was served to defendant by registered
mail due to time and distance constraints, and for lack of the undersigned’s staff who can serve the
same in person.

CHARLES ARUM