Motion For Substitution Catbagan
Motion For Substitution Catbagan
EVELYN CATBAGAN,
Plaintiff,
CIVIL CASE No. 2019-12
-versus- FOR: Unlawful Detainer
JOSE BARTOLAY.
Defendant.
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Undersigned Attorney unto this Honorable Court most respectfully states that:
1. Plaintiff died last February 23, 2019. Attached herewith is a copy of his
Certificate of Death.
3. It is prayed that all summons, orders and processes of the court be sent and
addressed to MARKER B. CATBAGAN at 356/1503 (B) Parejo St.,Sto. Niño De
Culdesac, Sun Valley, Parañaque City.
PRAYER
Other reliefs, just and equitable under the premises are likewise prayed for.
COS GUEVARRA
& ASSOCIATES LAW OFFICES
Counsel for the Plaintiff
Unit 210 Doña Eusebia Rodriguez Bldg.,
0611 Quirino Ave., san Dionisio, Parañaque City
Tel. No.825-99-18/ 09989984009
By:
EXPLANATION
Pursuant to Rule 13, Section 11 in relation to Section 6 of the 1997 Rules of Civil
Procedure, the service and filing of the foregoing Motion for Substitution of Plaintiff
was made to the counsel of defendant through LBC due to the lack of personnel and
sufficient resources to effect service and filing by personal delivery.
NOTICE OF HEARING:
Clerk of Court
MTC-Branch 88
Paranaque City
Please submit this motion for the consideration of the Honorable Court without
need for further hearing in view of the above circumstances.
Copy furnished: