12 lift order

REPUBLIC OF THE PHILIPPINES FIRST JUDICIAL REGION MUNICIPAL TRIAL COURT IN CITIES Branch 1, Baguio City UNI BANK, Co. Plaintiff - versus - CIVIL CASE NO. 69980 ROBIN K. YLLANA , Defendant. x - - - - - - - - - - - - - - -x MOTION FOR RECONSIDERATION (to Set Aside Order of Default and to Admit Attached Answer) DEFENDANT, assisted by the undersigned counsel, respectfully states that: 1. Defendant was declared to be in default on September 11, 2019 when she failed to file her answer within the reglementary period. 2. Defendant pleads for a reconsideration of the said Order for the reason that she did not receive a copy of the complaint nor any summons from this Honorable Court regarding the above cited case. She only received on August 30, 2019 a copy of the Order dated September 11, 2019, already declaring her in default. She immediately sought assistance from the Public Attorney's Office to avail of any remedies. 3. In the interest of substantial justice and for the reason earlier stated, defendant requests the compassion of this Honorable Court to admit her attached Answer. 4. Delay in the proceedings of this case was never intended. PRAYER WHEREFORE , premises considered, it is respectfully prayed of this Honorable Court to set aside the Order of default and to admit the attached Answer. Other just and equitable remedies are likewise prayed for. Baguio City, September 20, 2019. ATTY. TREMORLYN E. GALLENTE Counsel for the Defendants Room 9 Lopez Bldg., Session Road, Baguio City PTR No. 2190759; 05/03/2019; Baguio City IBP OR No: 1008020; 05/03/2019; Baguio City Roll No.: 69888; 04/09/2019 Baguio City, Philippines TIN No. 500-285-659-000

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lift order in default

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REPUBLIC OF THE PHILIPPINESFIRST JUDICIAL REGION

MUNICIPAL TRIAL COURT IN CITIESBranch 1, Baguio City

UNI BANK, Co.Plaintiff

- versus -CIVIL CASE NO. 69980

ROBIN K. YLLANA, Defendant.x - - - - - - - - - - - - - - -x

MOTION FOR RECONSIDERATION(to Set Aside Order of Default and

to Admit Attached Answer)

DEFENDANT, assisted by the undersigned counsel, respectfully states that:

1. Defendant was declared to be in default on September 11, 2019 when she failed to file her answer within the reglementary period.

2. Defendant pleads for a reconsideration of the said Order for the reason that she did not receive a copy of the complaint nor any summons from this Honorable Court regarding the above cited case. She only received on August 30, 2019 a copy of the Order dated September 11, 2019, already declaring her in default. She immediately sought assistance from the Public Attorney's Office to avail of any remedies.

3. In the interest of substantial justice and for the reason earlier stated, defendant requests the compassion of this Honorable Court to admit her attached Answer.

4. Delay in the proceedings of this case was never intended.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed of this Honorable Court to set aside the Order of default and to admit the attached Answer.

Other just and equitable remedies are likewise prayed for.

Baguio City, September 20, 2019.

ATTY. TREMORLYN E. GALLENTECounsel for the Defendants

Room 9 Lopez Bldg., Session Road, Baguio CityPTR No. 2190759; 05/03/2019; Baguio City

IBP OR No: 1008020; 05/03/2019; Baguio CityRoll No.: 69888; 04/09/2019

Baguio City, PhilippinesTIN No. 500-285-659-000

NOTICE OF HEARING