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Motion To Withdraw Hoshiya

1) Reynalyn Eduardo-Hoshiya filed a petition for judicial recognition of a foreign divorce from Hiroaki Hoshiya. 2) Due to the COVID-19 pandemic, pertinent documents cannot be presented to the court within a reasonable time. 3) Petitioner's counsel moves to withdraw the petition and unclog the case from the court's docket so as not to waste the court's time.

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740 views3 pages

Motion To Withdraw Hoshiya

1) Reynalyn Eduardo-Hoshiya filed a petition for judicial recognition of a foreign divorce from Hiroaki Hoshiya. 2) Due to the COVID-19 pandemic, pertinent documents cannot be presented to the court within a reasonable time. 3) Petitioner's counsel moves to withdraw the petition and unclog the case from the court's docket so as not to waste the court's time.

Uploaded by

edcelquiben
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

REGIONAL TRIAL COURT


Malolos City, Bulacan
Branch 80

REYNALYN B. EDUARDO-HOSHIYA,
Petitioner,
CIVIL CASE NO. 478-M-2015
-versus FOR: Judicial Recognition of
Foreign Divorce
HIROAKI HOSHIYA,
Defendant.
x--------------------------------------------x

MOTION TO WITHDRAW

Petitioner, by the undersigned counsel, respectfully move to


withdraw as he hereby withdraws his Petition for Judicial Recognition of
Foreign Divorce on the following grounds:

1) That due to the unforeseen circumstances that brought by the


pandemic COVID-19 pertinent documents cannot be presented
to this Honorable Court within a reasonable time;

2) And to unclog this case from this Honorable Court so as not


waste its precious time.

PRAYER

WHEREFORE, on the grounds afore-cited, it is respectfully moved


and prayed of this Honorable Court that the instant petition be ordered
withdrawn.

Other reliefs just and equitable under the premises are likewise
prayed for.

August 25, 2020. City of San Jose del Monte, Bulacan.


WARLITO DM. GOGOLIN
WARLITO DM. GOGOLIN LAW OFFICE
San Francisco St., Brgy. Poblacion I
City of San Jose del Monte, Bulacan
Roll No. 52714
PTR No. 2279808; 1/02/2020; CSJDM, Bulacan
IBP No. 102535; 1/03/2020; Bulacan
MCLE Comp. VII No. 0002403; 02/13/2020

With my conformity:

REYNALYN B. EDUARDO-HOSHIYA

NOTICE OF HEARING and Copy Furnished to:

THE BRANCH CLERK OF COURT


REGIONAL TRIAL COURT
Malolos City, Bulacan
Branch 80

OFFICE OF THE PROVINCIAL PROSECUTOR


City of Malolos, Bulacan

GREETINGS:

Please submit the foregoing motion for the consideration and approval of
the Honorable Court immediately upon receipt hereof. Thank You.

WARLITO DM.
GOGOLIN

Copy Furnished:

HIROAKI HOSHIYA
Blk 58 Lot 41 Canada St., Harmony Hills
Brgy. Muzon, City of San Jose del Monte, Bulacan

OFFICE OF THE PROVINCIAL PROSECUTOR


City of Malolos, Bulacan

EXPLANATION

In compliance with Rule 13 Section 11 of Rules of Court, service


by registered mail, of the foregoing Motion to the other party was resorted
due to distance and lack of personnel to effect personal service.
WARLITO DM.
GOGOLIN

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