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Republic of the Philippines

REGIONAL TRIAL COURT


SECOND JUDICIAL REGION
Branch 14
Lagawe, Ifugao

PEOPLE OF THE PHILLPINES, CRIMINAL CASE NO: 98-1034


Plaintiff,
-Versus-

CARIO LUNAG,
Accused.

CRIMINAL CASE NOS: 2124 &


-Versus- 2177

JOH NNY WEGET,


Accused.

-Versus- CRIMINAL CASE NO: 2050

AMBOY LINA,
Accused.

CRIMINAL CASE NO: 2056


-Versus-

TALIN ARGUEZA,
Accused.

URGENT EX PARTE MOTION FOR


POSTPONEMENT

WITH UTMOST REVERENCE TO THIS HONORABLE COURT

Undersigned counsel most respectfully submits this motion and for this
purpose avers that

1. Herein counsel is supposedly to appear before this Honorable Court


tomorrow December 11, 2013 at 9:00 oclock in the morning, to attend
the hearing of the above-entitled cases;

2. Regrettably on December 10, 2013, when counsel was already preparing


to travel to Ifugao from Baguio City in time to catch the hearing of the
foregoing cases, the pain at the lower left flank of his back which he was
suffering a couple of weeks earlier suddenly became more excruciating
that even sends a rather stinging sensation towards his butt and groin
area. Worse, the pain was coupled with an intermittent dizziness spell;

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3. Forthwith, undersigned counsel who was accompanied by his wife right
away sought medical attention at the SLU Hospital of the Sacred Heart,
Baguio City. Although there is no final diagnosis yet, initial findings
would suggest that counsel could be passing out some kind of kidney
stone/s. He was prescribed with some medicines for the meantime and
further advised by his doctor to take 3 to 5 days rest if only to observe
whatever developments there be. (A true and faithful reproduction of his
Medical Certificate and the Prescription of the attending Urologist is
respectively marked as ANNEX A and ANNEX B and to attached to
form part hereof)

4. With the foregoing dilemma, counsel is constrained to implore the


consideration and kindheartedness of this Honorable Court to cancel the
hearing of the above-captioned cases and reset the same on January 7,
2014 at 9:00 oclock in the morning;

5. This motion is neither tainted with malice nor meant to delay the
disposition of these cases but only due to foregoing reason.

RELIEF

WHEREFORE, premises considered, it most respectfully prayed of this


Honorable Court that this Motion be GRANTED.

Such other reliefs that may be just and equitable under the premises are also
prayed.

RESPECTFULLY SUBMITTED. This 10th day of December 2013 at Baguio


City for Lagawe, Ifugao, Philippines.

ATTY. RAYMOND G. PANHON


-Counsel/Movant-
Room #2, 3rd Floor, Rillera Building
No.7 Dagohoy Street, Baguio City 2600
PTR No: 4472212/ June 26, 2013/Lagawe, Ifugao
IBP No: 907725/ November 8, 2013/Ifugao Chapter
Roll No: 55498/May2, 2008/Manila
MCLE Compliance No. IV 0008053/Sept. 24, 2012
Mobile No. 09277997522
Email: raymondpanhon@yahoo.com

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REQUEST

ATTY. PASCUAL D. KIMAYONG, JR.


Clerk of Court
Regional Trial Court-Branch 14
Lagawe, Ifugao

Sir:

Greetings! Please submit the foregoing motion for the favorable action of the
Honorable Court immediately upon receipt hereof sans further oral arguments.
Thank you.

RAYMOND G. PANHON

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