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Summons Arayat

1) Plaintiff Arnanie Andres Acosta filed a complaint against Arayat Express Inc., Chito Oronce, and Jonathan Tibunsay Mejia for damages. 2) Defendant Chito Oronce filed an answer denying any connection to Arayat Express Inc. 3) Plaintiff is now requesting the court issue a summons to be served on Arayat Express Inc. separately to properly determine the issues and liabilities of the defendants.

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Bianca Taylan Pastor
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291 views2 pages

Summons Arayat

1) Plaintiff Arnanie Andres Acosta filed a complaint against Arayat Express Inc., Chito Oronce, and Jonathan Tibunsay Mejia for damages. 2) Defendant Chito Oronce filed an answer denying any connection to Arayat Express Inc. 3) Plaintiff is now requesting the court issue a summons to be served on Arayat Express Inc. separately to properly determine the issues and liabilities of the defendants.

Uploaded by

Bianca Taylan Pastor
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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REPUBLIC OF THE PHILIPPINES

First Judicial Region


MUNICIPAL CIRCUIT TRIAL COURT
Banna-Nueva Era, Ilocos Norte

ARNANIE ANDRES ACOSTA,


Plaintiff,

-versus- CIVIL CASE No. ______


For: DAMAGES
ARAYAT EXPRESS, INC., CHITO
ORONCE, Owner/ Manager of
ARAYAT EXPRESS, INC., and/or
JONATHAN TIBUNSAY MEJIA,
Defendants.
x------------------------------------------x

MANIFESTATION AND
MOTION FOR THE ISSUANCE OF SUMMONS

COMES NOW, plaintiff, through the undersigned counsel, and unto


this most Honourable Court, respectfully manifests: That -

On September 24, 2019, plaintiff filed a complaint against Arayat


Express, Inc., Chito Oronce, and Jonathan Tibunsay Mejia for DAMAGES;

On November 6, 2019, plaintiff received a copy of Defendant Chito


Oronce’s Answer dated October 28, 2019, wherein said defendant denied
any connection with the defendant corporation Arayat Express Inc.

In view of the allegation of defendant Oronce but without necessarily


admitting the same, plaintiff respectfully prays for the issuance of separate
Summons to be served upon defendant corporation Arayat Express Inc. with
business address at San Nicolas, Arayat, Pampanga, in order that there may
be a proper determination of the issues and liabilities of the defendants.

It is not the intention of the undersigned counsel to delay the speedy


dispostion of the instant case but only for the above-stated reasons.

WHEREFORE, above premises considered, it is most respectfully


prayed of this Honourable Court to issue Summons to be served upon
defendant Arayat Express, Inc.
Other reliefs that are just and equitable under the premises are
likewise prayed for.

RESPECTFULLY & COURTEOUSLY SUBMITTED. Laoag City for


Banna, Ilocos Norte, Philippines. December 6, 2019.

ATTY. JASON BADER LL. PERERA


Counsel for Plaintiff
Roll of Attorney’s No. 54820 / 30 April 2008
IBP No. 062278 / L.C. - 01/04/2019
PTR NO.1766978 / L.C. - 01/03/2019
MCLE No. VII-0000263, 07/30/2019
Manuel, Nicolas & Perera Law Offices
Brgy. 6, #62, Rizal St., Laoag City
Mobile Phone No. +639207042030

NOTICE

THE CLERK OF COURT


6th Municipal Circuit Trial Court
Banna-Nueva Era

Greetings! Kindly submit the foregoing motion on December 16,


2019 at 8:30 in the morning or at any date and time convenient to this
Honourable Court for consideration and approval of the same sans any oral
arguments.

ATTY. JASON BADER LL. PERERA

Copy Furnished by Registered Mail:


CHITO ORONCE/ARAYAT EXPRESS INC.
Purok 1, San Jose Mesulo,
Arayat, Pampanga

JONATHAN TIBUNSAY MEJIA


Brgy. Gen. Ricarte Llaner, Nueva Ecija

EXPLANATION ON MODE OF SERVICE

The foregoing motion is being filed and served through registered mail
due to distance, time constraints and lack of personnel to effect personal
service.

ATTY. JASON BADER LL. PERERA

REPUBLIC OF THE PHILIPPINES First Judicial Region MUNICIPAL CIRCUIT TRIAL COURT Banna-Nueva Era, Ilocos Norte ARN
Other reliefs that are just and equitable under the premises are likewise prayed for. RESPECTFULLY & COURTEOUS

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