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

FOR EXTRATERRITORIAL SERVICE OF SUMMON 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 defendant is already residing in 6/10 Smith

Street, NEUTRAL BAY NSW 2055, AUSTRALIA, and this case affects
the property of the defendant, plaintiff most respectfully move with
leave of court to serve summons by publication; and

3. That Summon by Publication be effected through the Department of

Foreign Affairs in Australia and by sending a copy of the publication
and order of the court by registered mail to the defendant’s last
known address in the Philippines.

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. 23456/1-12/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