MOTION PRIMARY STATEMENT BODY PRAYER NOTICE OF HEARING N.O.H.

ADDRESSED TO:

COMES NOW, the undersigned counsel for The Branch Clerk of

MOTION FOR Prayer (postponement Name and Address of
1 plaintiff and to this Honorable Court respectfully 5 sentences w/ Notice of Hearing Court, RTC, Branch,
POSTPONEMENT and reschedule) Opposing Counsel
alleges: Address

Prayer (declare
COMES NOW, the undersigned counsel for The Branch Clerk of
MOTION TO DECLARE defendants in default Name and Address of
2 plaintiff and to this Honorable Court respectfully 2 sentences w/ Notice of Hearing Court, RTC, Branch,
DEFENDANTS IN DEFAULT and be allowed to Opposing Counsel
alleges: Address
present evid ex parte)

COMES NOW, the undersigned counsel for Prayer (respectfully pray

defendant and to this Honorable Court respectfully that attached AMENDED
moves for leave to amend his ANSWER already ANSWER be admitted in
MOTION FOR LEAVE TO Name and Address of
3 filed, dated _______, and for this purpose hereby order that real matter in w/ Notice of Hearing
AMEND ANSWER Opposing Counsel
presents the attached AMENDED ANSWER dispute and all matters in
wherein the amendments sought to be incorporated this action may be
are indicated by being underscored. completely determined)

COMES NOW, the undersigned counsel for the

defendant and to this Honorable Court respectfully
ARGUMENTS
moves to dismiss the plaintiff's complaint on the
following grounds: Prayer (plaintiff's
A. State ground and complaint be dismissed Name and Address of
4 MOTION TO DISMISS w/ Notice of Hearing
1. claim of p.tiff in the complaint has been released reason to support the first with costs against Opposing Counsel
ground plaintiff)
B. State ground and
2. claim or demand is unenforceable under the
reason to support the 2nd
provisions of the Statute of Frauds
ground
Prayer (issuance of an
Order by this Honorable
COMES NOW, the undersigned counsel for the Court requiring the p.tiff
MOTION FOR BILL OF Name and Address of
5 defendant and to this Honorable Court respectfully 3 sentences to make more definite w/ Notice of Hearing
PARTICULARS Opposing Counsel
alleges: and certain his complaint
in the particulars above
indicated)
 COMES NOW, the undersigned counsel for Prayer (respectfully pray
defendant and to this Honorable Court respectfully that attached AMENDED
moves for leave to amend his ANSWER already ANSWER be admitted in
MOTION FOR LEAVE TO FILE Name and Address of
6 filed, dated _______, and for this purpose hereby order that real matter in w/ Notice of Hearing
AMENDED PLEADINGS Opposing Counsel
presents the attached AMENDED ANSWER dispute and all matters in
wherein the amendments sought to be incorporated this action may be
are indicated by being underscored. completely determined)
Prayer (that this Hon.
COMES NOW, the undersigned counsel for Court direct judgment on
MOTION FOR JUDGMENT ON Name and Address of
7 plaintiff and to this Honorable Court respectfully 3 sentences the pleadings pursuant w/ Notice of Hearing
THE PLEADINGS Opposing Counsel
alleges: to Rule 19 of the Rules
of Court)
Prayer (that the
COMES NOW the plaintiff and defendant, foregoing compromise
The Branch Clerk of
MOTION FOR JUDGMENT ON assisted by their respective counsels, and to the agreement be approved
2 sentences may or may not have notice Court, RTC, Branch,
COMPROMISE Honorable Court respectfully submit the following and that judgment be
8 Address (if with n.o.h)
compromise agreement: rendered in accordance
therewith)
By: Plaintiff By: Defendant
put this after the prayer:
Assisted by: Law Firm, Address Assisted by: Law Firm, Address
COMES NOW the plaintiff/defendant in the above
entitled case, by the undersigned counsel and to
this Honorable Court respectfully moves to set ARGUMENTS
aside its judgment rendered therein dated _____
and to grant a new trial on the following grounds:

State the grounds. Point

out specifically the findings Prayer (that judgment
of the judgment w/c are herein dated ___ be set Name and Address of
9 MOTION FOR NEW TRIAL w/ Notice of Hearing
not supported by the aside and a new trial Opposing Counsel
1. evid adduced in this Court is insuffcient to evidence or which are granted)
justoify the said complaint; 2. contrary to law, making
judgment has no basis as against the facts express reference to the
presented during the hearing of this case testimonial or documentary
evidence or to the
provisions of law alleged to
be contrary to such
findings or conclusions
 Prayer (service of
summons in the above-
entitled case be effected
MOTION FOR LEAVE TO COMES NOW, the undersigned counsel for
upon the defendant by
10 SERVE SUMMONS BY plaintiff and to this Honorable Court respectfully 4 sentences COPY FURNISHED
publication in such
PUBLICATIONS alleges:
places and for such
times as the Court may
order)
Prayer (that the
He is the counsel of record appearance of the
for the petitioner in the undersigned counsel for
above entitled case. the petitioner be
considered withdrawn.
Due to his impending trip
to US to attend the major
operation of his father, the
The Branch Clerk of
MOTION FOR WITHDRAWAL COMES NOW, the undersigned counsel and to undersigned counsel is Name and Address of
11 w/ notice of hearing Court, RTC, Branch,
OF APPEARANCE this Honorable Court respectfully states: constrained to withdraw, Opposing Counsel
after prayer put this: Address
as he hereby withdraws
WITH OUR
his appearance as counsel
CONFORMITY
for the petitioners whose
Petitioners
conformity hereto had
been graciously given after
explaining the details of
the above mentioned
reason
Prayer (judgment
rendered against __ as
COMES NOW, the undersigned counsel of the
the third party defendant
MOTION FOR LEAVE TO FILE defendant and with leave of court,files this third
12 3 sentences for ____ and for such
THIRD PARTY CLAIM party complaint against ____, hereinafter called the
other relief consistent
third party defendant, and respectfully avers:
with law and equity for
costs)
w/ notice to COC to submit
Prayer (that these cases the Motion for Consolidation
COMES NOW, the prosecution, by undersigned
MOTION FOR be consolidated, raffled to the Hon. Court for its
13 Asst. City Prosecutor and to this Honorable Court 3 sentences
CONSOLIDATION and assigned to only one consideration and approval
respectfully alleges:
branch of the Court. immediately upon receipt
hereof
 Prayer (that in the
interest of justice, an
order for physical
COMES NOW,the undersigned atty of the
MOTION FOR PHYSICAL examination of the Party to be examined and to all other parties,
14 movant(defendant) and to this Honorable Court 6 sentences w/ notice of hearing
EXAMINATION offended party be issued Address
respectfully alleges:
by this Hon. Court at the
time, place and manner
above indicated)

3. sentences (state that

intervenor has legal
interest in the matter in
litigation or in the success Prayer (that the
COMES NOW, the undersigned atty of the
of either parties, or an intervenor be permitted
intervenor and to this Honorable Court
interest against both, or to intervene in this action All parties to the original action with their
15 MOTION FOR INTERVENTION respectfully asks leave to file a complaint (or w/ notice of hearing
that he is so situated as to by filing a respective addresses
answer) in intervention in the above-entitled
be adversely affected by a complaint/answer in
case for the ff reasons:
distribution or other intervention)
distribution of property in
the custody of the court or
of an officer thereof)

NOTICE ADDRESSED TO BODY SENDER CONFORME COPY FURNISHED

The Clerk of Court, RTC, Branch __,
1 NOTICE OF APPEARANCE
City/Municipality
GREETINGS: Please enter the appearance of the
undersigned as attorney for the defendants in the
Name of Counsel for
above-entitled case. It is requested that the Name and Address of
Defendant, Address, PTR & Counsel of Plaintiff
undersigned be served and furnished with copies of Defendant.
IBP No., Atty's Roll No.
motions, orders, judgments and other papers
relevant to said case.

GREETINGS: Please take notice that in connection

with the Civil Case No. ___ of the RTC of ____
entitled "____", the deposition upon oral examination
NOTICE TO TAKE of witness __ residing at ___ who is unable to attend Name and Address of Counsel of Defendant,
2 Every Party to the action, Addresses
DEPOSITION and testify at the hearing of the above mentioned Counsel for Petitioner Address
case due to ___, will take place at __o'clock A.M. on
the day of _______ before, Notary Public for and in
_____.
 Please be notified that on ___ the plaintiff in the
above entitled case filed an action now pending for
trial in the RTC of ___ for (state the nature of action)
of certain parcels of land against the defendant ___,
which parcels of land are situated in ____ and more
Counsel for Plaintiff,
3 NOTICE OF LIS PENDENS Register of Deeds of ____ particularly described as folows:
Address, IBP & Roll No.
description of property
You are requested to record this notice of the
pendency of the above mentioned action at the back
portion of the title to above described property, for all
legal purposes.