Republic
of the Philippines
National
Capital Judicial Region
REGIONAL TRIAL COURT
xxx CITY
BRANCH xxx
X x x,
Plaintiff-Appellee,
-
Versus - Civil
Case No. xxx
X x x,
Defendant-Appellant.
X - - - - - - - - - - - - - - - - - - -
- - - - - X
xxx, 2015
URGENT
Mr. x x x
Deputy Sheriff
Office of the Clerk
of Court
Regional Trial Court
xxx City
RE : YOUR “NOTICE TO PAY/VACATE”,
DATED xxx, 2015.
MABUHAY:
In re: your NOTICE TO PAY/VACATE, dated xxx, 2015,
a copy of which was received on xxx,
2015, by our Client, i.e., Defendant-Appellant xxx, we
respectfully request that the said matter be deferred considering that that
there is now a pending Rule 65 Petition
for Certiorari in the Court of Appeals (CA), docketed as CA Case No. xxx, entitled “xxx
v. Hon. xxx and xxx”, praying for the setting aside of the Order,
dated xxx, 2015, which granted the issuance of a Writ of Execution Pending Appeal.
We are still waiting for the action of the CA on our prayer for a Temporary Restraining Order (TRO) included
in the said Petition. We are still in the process of inquiring and following up
with the CA the status thereof.
Simultaneous with
this Letter to you, we are filing the necessary Motion with the Regional Trial Court, Branch xxx, for the same
purpose.
For your information, xxx is 79 years old, widow,
jobless, and sickly. She lives in the subject property.
Thank you for your
kind and compassionate assistance.
Sincerely yours,
X
x x
LASERNA CUEVA-MERCADER
& ASSOCIATES LAW OFFICES
Counsel for the Defendant-Appellant
Unit 15, Star Arcade, C. V.
Starr Avenue
Philamlife Village, Las Pinas
City
Tel. Nos. 872-5443; 846-2539
X x x.
