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Motion For Leave Leg Forms
Motion For Leave Leg Forms
[email protected] By: Atty. Katerina Bianca C. Perez Roll No. 385769 IBP No. 874986/02-14-2012/Quezon City PTR No. 95857639/01-15-2013/Quezon City MCLE: April 22, 2013
REPUBLIC OF THE PHILIPPINES NATIONAL CAPITAL JUDICIAL REGION METROPOLITAN TRIAL COURT, BRANCH 12 QUEZON CITY
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Case No. 5501 MOTION FOR LEAVE TO FILE THIRD PARTY COMPLAINT
DEFENDANT, Mario Dinglasan, by counsel and to this Honorable Court, respectfully alleges: 1. Defendant has been sued on the basis of the multiple causes of action (Annex A of Complaint), which he and the Plaintiff entered in to a Contract of Consignment. Proviso of the Contract states that the Consignee-herein-Defendant was allowed to contract and employ a substitute/sub-agent by the Consignor-herein-Plaintiff. 2. Consignee-herein-Defendant contracted a certain Winley Joy Supnet to act and perform as a sub-agent. As such, the Consignee-hereindefendant is held liable due to the gross negligence of Mr. Supnet. 3. Winley Joy Supnet is of legal age, single, and is a resident of 180 Fitness First Street, Diliman, Quezon, Metro Manila.
4. Impleading Winley Joy Supnet would not delay the disposition of the case, and would in fact prevent multiplicity of suits. 5. The proposed third party complaint is attached hereto as Annex B. WHEREFORE, defendant prays that he be given leave of court to file the attached third-party complaint, and for such other reliefs as may be just and equitable in the premises.
PEREZ, PARK, KIM LAW OFFICE Counsel for Defendant Unit 8D, Madison Place, Cubao, Quezon City Contact Number: 419-37-28 [email protected]
By:
ATTY. KATERINA BIANCA C. PEREZ Roll No. 385769 IBP No. 874986/02-14-2012/Quezon City PTR No. 95857639/01-15-2013/Quezon City MCLE: April 22, 2013
NOTICE OF HEARING
GREETINGS: Please submit the foregoing motion for the consideration and approval of the Honorable Court on August 19, 2013 at 8:30 AM.
cc: DIGNO-SIBAL LAW OFFICE Counsel for Plaintiff 3rd Floor, 1990 Building, Eastwood City, Quezon City Tel No. 789-2712 [email protected]
EXPLANATION OF SERVICE Copy of the Motion for Leave of Court to file Third-Party Complaint was served to Plaintiffs counsel by registered mail due to time constraint and distance, and for lack of the undersigneds staff who can serve the same in person.