Sps Lao Case Urgent Ex_parte Motion To Postpone.docx

Republic of the Philippines 12th Judicial Region MUNICIPAL TRIAL COURT IN CITIES Cotabato City MARIAM V. GUIALANI Plaintiff,

CIVIL CASE NO. 3341

-vs-

-for-

SPS. ASSIDA A. LAO LININDING M. LAO FAISAL B. UNGKAKAY In his capacity as the OIC Register of Deeds of Cotabato City x------------------------------x

RECONVEYANCE OF TITLE WITH PRAYER FOR DAMAGES AND ATTORNEY’S FEES

URGENT EX-PARTE MOTION FOR POSTPONEMENT Undersigned counsels respectfully aver: 1. That the above-entitled case is scheduled for Hearing on March 6, 2019 (Wednesday). 2. That on March 5, 2019, at 5:00 PM, Defendants SPS. ASSIDA A. LAO and LININDING M. LAO set a meeting with us and decided to engage our legal services. It was during the said meeting that these counsels were informed that the Notice of Pre-Trial was received by them on March 4, 2019. 3. That due to time constraint we do not have sufficient time to peruse the records of the case and prepare for today’s pre-trial conference. 4. That this motion is filed in good faith.

PRAYER WHEREFORE, it is respectfully prayed that the hearing of the above-entitled case be reset to the next available calendar of the Honorable Court.

Other measures of relief are also prayed. Cotabato City, March 6, 2019.

ATTY. RAHMA D. SANGLITAN, CPA Roll of Attorney No. 70670 IBP OR No. 097780/ 01-07-2019 MCLE Compliance (Admitted June 4, 2018) PTR No. 3070569 / 01-04-2019 Unit 3B, MS Building , Don TV Juliano Avenue, RH12, Cotabato City

ATTY. NASIFF BRIAN O. MEDITAR, RN Roll of Attorney No. 72158 IBP OR No. 1071139 (01-28-2019; Cotabato City) MCLE Compliance (Admitted 06-20-2018) PTR No. 3070134 (01-04-2019; Cotabato City) Unit 3B, MS Building, Don TV Juliano Avenue, RH12, Cotabato City

ATTY. FAIZODEN P. ALI, CPA Roll of Attorney No. 70669 IBP OR No. 058522 (12-13-18; Manila) MCLE Compliance (Admitted 06-04-2018) PTR No. 3070570 (01-04-2019; Cotabato City) Unit 3B, MS Building, Don TV Juliano Avenue, RH 12, Cotabato City COUNSELS FOR THE DEFENDANTS

REQUEST THE CLERK OF COURT Municipal Trial Court in Cities Cotabato City Greetings: Kindly submit the foregoing motion for postponement to the kind consideration of the Honorable Court upon receipt thereof.

ATTY. RAHMA D. SANGLITAN, CPA ATTY. NASIFF BRIAN O. MEDITAR, RN ATTY. FAIZODEN P. ALI, CPA