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Urgent Motion (Manuel)

1) The respondent filed an urgent motion requesting that the court order allow her to take temporary custody of her child from the petitioner on weekends to strengthen the mother-child bond, as previously recommended. 2) When the respondent recently attempted to take custody of the child, the petitioner and his brother denied her access and claimed he should have custody of their other child as well, in defiance of the court order. 3) The respondent requests that the court issue an order directing law enforcement to enforce the existing court order granting the respondent weekend custody of the child to achieve the court's goal of establishing a good relationship between the child and both parents.

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264 views3 pages

Urgent Motion (Manuel)

1) The respondent filed an urgent motion requesting that the court order allow her to take temporary custody of her child from the petitioner on weekends to strengthen the mother-child bond, as previously recommended. 2) When the respondent recently attempted to take custody of the child, the petitioner and his brother denied her access and claimed he should have custody of their other child as well, in defiance of the court order. 3) The respondent requests that the court issue an order directing law enforcement to enforce the existing court order granting the respondent weekend custody of the child to achieve the court's goal of establishing a good relationship between the child and both parents.

Uploaded by

Patricia Castro
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOC, PDF, TXT or read online on Scribd
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Republic of the Philippines

REGIONAL TRIAL COURT


First Judicial Region
BRANCH 3
Baguio City

DEMPSEY G. CODAMON,
Petitioner, SPEC. PROC. CASE No. 2759–R

For:
- versus -
CUSTODY of the MINOR
DIXIE KATE M. CODAMON
JANICE B. MANUEL, (HABEAS CORPUS)
Respondent.
x---------------------------------------------x

URGENT MOTION

COMES NOW, the Respondent, through the undersigned counsel,


and unto this Honorable Court, most respectfully states that:

1) Based on the recommendation of the court social worker, the


Respondent-movant is given the right to take the subject child
from the temporary custody of the Petitioner on weekends so as
to strengthen the bond between mother and child, which was
discussed during the last hearing on 12 October 2018;

2) Pursuant to the above, in the evening of 16 November 2018,


respondent-movant, accompanied by her spiritual adviser,
Bernadeth Labagan, went to the residence of Petitioner but was
turned away by the petitioner’s brother, one Jhun Lagdao, citing
that she cannot take said child, which was likewise reiterated by
the petitioner, claiming that he should also be allowed to have
custody of the parties’ other child, Dempsey M. Codamon, Jr.;

3) The behavior of the petitioner and his gang of thugs is


plainly in defiance of the Honorable Court’s Order, thus, should
be sanctioned accordingly;

4) In the meantime, it has become imperative that a court order


be issued directing the Honorable Court’s Sheriff or any
operative of the Philippine National Police to achieve the goal of
this Honorable Court, i.e. the establishment of a good
relationship of the child with both parents, as stated in its Order
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dated 12 October 2018, on the 23rd of October 2018 and every
succeeding Friday, if necessary.

PRAYER

WHEREFORE, premises considered, it is so respectfully moved.

Other reliefs, just and equitable, are likewise prayed for.

This 19th day of November 2018, in the City of Baguio, Philippines.

A B S LAW OFFICES
Suite 305, Laperal Building
Session Road, Baguio City
(Tel. No. (074) 442-8243)

By:

JUAN ANTONIO REYES ALBERTO III


PTR No. 3418024/12.20.2017/Baguio City
IBP Life No. 01059/12.20.1996/Baguio City
MCLE V No. 0002889/07.03.2014
Roll No. 35781

NOTICE

The BRANCH CLERK of COURT


Regional Trial Court – Branch 3
Justice Hall, Baguio City

ATTY. GUILLERMO R. BANDONILL, Jr.


Counsel for the Petitioner
Room 307 Laperal Building
Session Road, Baguio City
2600 Philippines
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Greetings:

Please take notice that on 21 November 2018 at 8:30 a.m., or as


soon thereafter as counsel and the matter may be heard, the undersigned
will submit the foregoing Urgent Motion for the approval of the
Honorable Court.

JUAN ANTONIO REYES ALBERTO III

Copy furnished:

ATTY. GUILLERMO R. BANDONILL, Jr.


Counsel for the Petitioner
Room 307 Laperal Building
Session Road, Baguio City
2600 Philippines

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