Republic of the Philippines Republic National Capital Judicial Region METROPOLITAN TRIAL COURT City of Valenzuela, Branch 81 VIRGINIA LOVERAS, Plaintif,
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Ciil Case No! """""""" #or$ %nla&ful 'etainer
FELIZA FELI ZA CLEO CLEOF FAS, AS, and and all all persons claiming right of possession over her, her, Deendants. (----------------------------------------)
MANIFESTATION w/ MOTION FOR REPLACEMENT OF PROVISIONAL MARKINGS OF DOCUMENTAR DOCUMENTARY Y EXHIBITS EXHI BITS TO PERMANENT MARKINGS P*+N##, through the undersigned counsel, respectfully sub.its this .anifestation &ith .otion and in support thereof aers the follo&ing$ 1! 'uring the preli.inary conference of this case held on """"""", plainti/ proisionally .ar0ed the follo&ing docu.ents, &hich are photocopies of their original copies andor certi2ed true copies, to &it$ Proviio!" # M"r$i!% AABCDEFG-
Do&'()!*
P'r+o)
3! he plainti/ .ade the foregoing proisional .ar0 .ar0in ings gs &ith &ith the the nece necess ssar ary y unde undert rta0 a0in ing g that that she she &ill &ill sub.it the original copies andor certi2ed true copies &ith the 4onorable Court!
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5! %nfortunately, it &as only after the plainti/ had already sub.itted her position paper that she &as able to secure the original copies andor certi2ed true copies of the foregoing proisionally .ar0ed docu.ents hence she &as not able to attach the sa.e to the said position papers as her docu.entary e)hibits! 6! 7ith the foregoing, the plainti/ hu.bly .oes that she be allo&ed to sub.it the original copies andor certi2ed true copies &ith this 4onorable Court or co.pare these &ith the foregoing proisionally .ar0ed docu.ents for these to for. part of the records and be considered in the resolution of this case! ! n support of the plainti/9s herein hu.ble plea, the :upre.e Court in the case of P)!oo "!. P)!oo v Do!"0 declared that “Let it be emphasized that the rules of procedure should be viewed as mere tools designed to facilitate the attainment of justice. Their strict and rigid application, which would result in technicalities that tend to frustrate rather than promote substantial justice, must always be eschewed . Even the Rules o Court reect this principle ! ;<.phasis supplied= >! ?oreoer, the allo&ance of this plea &ould aid this 4onorable Court in arriing at a @udicious resolution of the issues and controersies and decision in this case considering that it &ill be able to consult the signi2cant docu.ents &hich erily reAect the rights of the plainti/s! ! #inally, the 2ling of this .otion is &ithout any intent to delay the proceedings of this case to the pre@udice of the parties but due solely to the aboe stated grounds! PRAYER ACCORDINGLY , it is .ost respectfully prayed of this 4onorable Court to ALLO1 the Plainti/, Virginia *oeras, to SUBMIT the riginal Copies andor Certi2ed rue Copies of the proisionally .ar0ed docu.ents and for this 4onorable Court to RECEIVE these as the docu.entary e)hibits of the said plainti/!
ther .easures of relief, @ust and eDuitable under the pre.ises, are li0e&ise prayed for! 1
E!R! No! 16F18, F5 +pril 3FFG
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City of ?anila for City of Valenzuela, 11 Noe.ber 3F1! By$ ALLAN DUANE A MENDOZA Counsel or the Plaintif :uite 3F5, 5FI1 PR No! 58356G 13-35-16G ?+N*+ for 3F1K BP No! FI813F1G F1-F-1G ?+N*+ ?C*< <(
Please 0indly sub.it the foregoing .otion for hearing on 23 Nov)(4)r 2506 "* 7835 o9&#o&$ i! *:) (or!i!% or at a later date and ti.e conenient to the schedule of this 4onorable Court! he apparent long schedule of proposed hearing of the aboe .otion is due to the fact that Noe.ber 1 to 3F are declared holidays because of the +P
DUANE
A
MENDOZA Cop! urnished" ATTY ;OHN ;OHN B CARABBACAN Counsel or the deendants P%B*C +RN
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he original copy of the foregoing ?anifestation &ith ?otion &as 2led &ith this 4onorable Court and a copy thereof &as sered to the counsel for the defendants both through registered .ail due to ti.e and personnel constraints! ALLAN
DUANE
A
MENDOZA
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