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    Motion To Expedite

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    Marky Cielo
    The defendant Rural Bank of Rizal filed an ex-parte motion to expedite the forwarding of the case to the proper court. The presiding judge had recused herself due to close family relations with the plaintiff bank. However, the order was only received by counsel in December 2018. The motion requests that the case, which involves qualified theft complaints filed in 2011, be promptly forwarded to the executive judge or Supreme Court to be assigned and heard without further delay.

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    Motion To Expedite

    Uploaded by

    Marky Cielo
    362 views2 pages
    The defendant Rural Bank of Rizal filed an ex-parte motion to expedite the forwarding of the case to the proper court. The presiding judge had recused herself due to close family relations with the plaintiff bank. However, the order was only received by counsel in December 2018. The motion requests that the case, which involves qualified theft complaints filed in 2011, be promptly forwarded to the executive judge or Supreme Court to be assigned and heard without further delay.

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    motion to expedite

    Original Title

    Motion to Expedite

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    The defendant Rural Bank of Rizal filed an ex-parte motion to expedite the forwarding of the case to the proper court. The presiding judge had recused herself due to close family relations with the plaintiff bank. However, the order was only received by counsel in December 2018. The motion requests that the case, which involves qualified theft complaints filed in 2011, be promptly forwarded to the executive judge or Supreme Court to be assigned and heard without further delay.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    362 views2 pages

    Motion To Expedite

    Uploaded by

    Marky Cielo
    The defendant Rural Bank of Rizal filed an ex-parte motion to expedite the forwarding of the case to the proper court. The presiding judge had recused herself due to close family relations with the plaintiff bank. However, the order was only received by counsel in December 2018. The motion requests that the case, which involves qualified theft complaints filed in 2011, be promptly forwarded to the executive judge or Supreme Court to be assigned and heard without further delay.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    You are on page 1of 2

    Republic of the Philippines

    REGIONAL TRIAL COURT


    9th Judicial Region
    Branch 1
    Calamba, Misamis Occidental

    PEOPLE OF THE PHILIPPINES CRIM. CASE NO. 1649, 1650,


    Plaintiffs, 1651, 1652, 1653,
    1654, 1655 and
    16566
    -versus-
    ROWENA CULANAG DELOS REYES FOR: QUALIFIED THEFT
    And CELESTE MAKINTURA FLORA
    Defendant,
    x------------------------------------------/

    EX-PARTE MOTION
    (TO EXPEDITE THE FORWARDING OF THE CASE
    TO A PROPER COURT)

    COMES NOW the Defendant, RURAL BANK OF RIZAL, Inc. (herein,


    Bank), through the undersigned counsel, appearing especially for this
    purpose, and to this most Honorable Court, most respectfully moves that the
    court expedite it’s order to forward the case to the Executive Judge for its
    proper disposition and to have such case assigned to the appropriate
    Regional Trial Court Branch for the recommencement of the case, at the
    earliest possible time.

    DISCUSSION

    1. An Order form the distinguished acting judge of this court – Judge


    Cherry Joy C. Concha-Ageas – was issued on September 17, 2018
    that manifested her voluntary recusion from handling the above-
    captioned cases on the ground of close blood relations with the
    President of the Private Complainant Bank (Rizal Rural Bank, through
    Atty. Albert T. Concha Jr.).

    2. However, such order was only received by herein counsel on


    December 12, 2018 and noting the year-end holidays for the Judiciary,
    the herein counsel has promptly filed this motion.

    Page 1 of 2
    3. Upon inquiry with the Acting Clerk of Court of this most honorable
    Court, it appears that there has been no communiqué, order or
    resolution that would effectuate the immediate and expeditious
    forwarding of the case to the Executive Judge or to the Supreme
    Court, whichever is proper, so as to have the case be docketed and
    finally heard by a court.

    4. It is an opportune time to highlight that the herein private complainant


    had filed the formal complaints against accused in August 2011 – over
    eight (8) years now.

    5. This motion is filed with utmost respect to the court and with honest
    belief that there is no other recourse other than to file this motion to
    preserve the rights of the herein Private Complainant.

    PRAYER

    WHEREFORE, it is respectfully prayed that the Most Honorable Court


    direct its Clerk of Court to forward the above-captioned case to the proper
    governing body – be it the Executive Judge of this courts Jurisdiction or the
    Supreme Court – with whomever the court deems proper, and to do so
    expeditiously and without unwarranted delay.

    Other reliefs just and equitable are likewise prayed for.

    Dipolog City, Philippines, January 8, 2019.

    Diana Charlette G. Concha

    NOTICE OF HEARING

    THE BRANCH CLERK OF COURT


    RTC - Calamba
    Calamba, Misamis Occidental

    Greetings!

    Kindly submit the foregoing motion for consideration and approval of


    this Honorable Court immediately upon receipt hereof without further
    argument.

    Diana Charlette G. Concha

    Page 2 of 2

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