Republic of the Philippines

7th Judicial Region

MUNICIPAL TRIAL COURT
City, Province

XXXXXXXXXXXXXXXXXXX Civil Case No. 123

Plaintiff, For: Specific Performance
and Damages

-versus-

XXXXXXXXXXXXXXXXXXX
Defendant.
X-------------------------------------------/

URGENT MOTION FOR POSTPONEMENT

Counsel for Plaintiff, before this Honorable Court, most

respectfully states:

1. That the above-entitled case is set for Hearing of

Plaintiff’s fourth witness on September 19, 2018 at
10:00 o’clock in the morning;

2. That the undersigned counsel for the plaintiff, ATTY.

ABCDEFG, is supposedly ready for the said hearing,
however, the witness police officer, PO1 John dela Cruz
is unavailable on September 19, 2018 due to urgent
family matters to attend to.

3. That this particular request for resetting is based on the

aforementioned reason, which is urgent and in no way
intended to delay the proceedings of the above-entitled
case;

WHEREFORE, premises considered, counsel for

Plaintiff most respectfully pray that the next hearing for the
above-entitled case scheduled on September 19, 2018 at
10:00 o’clock in the morning be postponed/cancelled and
shall proceed either on October 03, 10, 17, 24, 31, 2018 or
any other date in November of 2018.

XXXXX, Province, September 17, 2018.

1
 ATTY. ABCDEFG
Counsel for the Plaintiff
01 A. Makahiya Street
XXXXX City, 1234, Province of XXX, Philippines
Roll No. 123456 : May 21, 2000
IBP No. 1234567
MCLE Compliance No. VI-0001111 : February 23, 2018
PTR No. 000000: 01-03-2018: XXXXX City
TIN: 111-222-333
Mobile No. 09321234567

Copy furnished:

ATTY. YYYYYYYYY
Received by:
Counsel for Defendant
YYYYYYYY Law Office Signature: _______________
2/F, Daisy Building Name: __________________
XXXXX, Province of Date: ___________________

*************

Acting Clerk of Court

Municipal Trial Court
City, Province

Ms. Clerk of Court,

Please submit this Urgent Motion to the Honorable

Court upon receipt hereof for Your Honor’s consideration.

Thank you.

ATTY. ABCDEFG