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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT OF ILOILO CITY

6th

JUDICIAL REGION

Branch 10

JOKO LOKO Civil Case no. 52122

Plaintiff, For: Damages

-versus

LUKE KULE

Defendant,

x-----------------------------x

MOTION FOR RECONSIDERATION

COMES NOW, plaintiff, through the undersigned counsel, most respectfully avers that:

1) Plaintiff, through counsel, received on February 13, 2013 an Order dated February11, 2013 from this Honorable Court declaring the plaintiff in default. The 15-day period to file a

Motion for Reconsideration to the said order ended on February 25, 2013. However, since

February 25, 2013 fell on a legal holiday, the said Motion for Reconsideration may be filed

today. Hence, the said Motion for Reconsideration is deemed filed within the reglementary

period;

2) With all due respect to the Honorable Court, plaintiff would like to seekreconsideration of its Order dated February 11, 2013;

3) Notwithstanding the said order, plaintiff does not intend to waiver fromprosecuting the above-entitled case, considering that such is a meritorious case and he is within

his rights in filing the same. Unfortunately, though the plaintiff received a copy of the notice of

pre-trial, his counsel was not given a separate copy thereof;

4) In the interest of justice, the reconsideration of the Order dated February 11, 2013of this Honorable Court is in order.

WHEREFORE, plaintiff most respectfully prays of this Honorable Court that the Order

dismissing the case without prejudice dated February 11, 2013 be reconsidered and set aside in

the interest of justice.

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RESPECTFULLY SUBMITTED.

Iloilo City, Philippines, February 26, 2013.

Counsel for the Plaintiff

THE BRANCH CLERK OF COURT

Regional Trial Court

Branch 10, Iloilo City

Greetings:

Please submit the foregoing motion for the consideration and approval of the Honorable

Court on March 15, 2013, Friday, at 8:30 oclock in the morning, without oral argument.

-N O T I C E-

Counsel for the Defendant

Greetings:

Please take note that undersigned counsel will submit the foregoing motion for the

consideration and approval of the Honorable on March 15, 2013, Friday, at 8:30 oclock in the

morning, without oral argument.

Copy furnished by personal service to:

Counsel for the Defendant

Received by: __________________

Date: ________________________

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Explanation

Pursuant to Section 13, Rule 13, Rules of Court, service of the foregoing motion to theCounsel of the defendant is by personal service as evidenced by the official return/proof of

service of the server.