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114Wrong Sent

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  • vic ceballos
    Dec 20, 2007
      Sorry chillout lawyers wannabe for that wrong sent pleading.  Was going to attach your final exam results and recitations so you may see that I am all set to compute your grades save for the fact that I have not yet received the DVDs from each group (apart from what Ipe has consolidated as part of his group's wrap-up) with DVD covers and sticker/label on the DVD, showing your smiley faces and names. Put a title too for the video you made.
       
      But last minute, I decided not to attach them anymore as some people may not want others to see their individual grades- a matter of privacy issue. 
       
      I hope to get the above-mentioned items from you on or before Dec. 29, thru Atty. TJ, who stays near the Katipunan area. 
       
      You all have a merry chillout Christmas!!
       
      Your Companero 

      ----- Original Message ----
      From: vic ceballos <chilloutprof@...>
      To: chilloutprovrem@yahoogroups.com
      Sent: Thursday, December 20, 2007 5:51:43 PM
      Subject: [chilloutprovrem] (unknown)



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      -----Inline Attachment Follows-----

      {\rtf1\ansi\ansicpg1252\deff0\deflang1033{\fonttbl{\f0\fswiss\fcharset0 Verdana;}{\f1\froman\fcharset0 Times New Roman;}}
      {\*\generator Msftedit 5.41.15.1503;}\viewkind4\uc1\pard\qc\b\f0\fs24 REPUBLIC OF THE PHILIPPINES\par
      OFFICE OF THE PROSECUTOR\par
      MAKATI CITY \par
      \par
      \par
      \par
      \pard\qj BANK OF COMMERCE, \par
      \tab\tab\tab Complainant,\par
      \par
      \par
      \tab - versus -\tab\tab\tab\tab\tab I.S NO. __________\par
      \par
      \par
      JOSELTIO TAMBUNTING ,\par
      \tab\tab\tab Respondent.\par
      x-------------------------------------x\par
      \par
      \par
      \pard\qc\fs28 MOTION TO REOPEN CASE \fs24\par
      \pard\qj\par
      \par
      \pard\sl480\slmult1\qj\tab\b0 Respondent, through undersigned counsel, and unto this Honorable Office of the Prosecutor, hereby avers the following, to wi:\par
      \par
      \tab 1.\tab His counter-affidavit was supposed to have been submitted on December 12, 2007.  However, he was not able to submit the same as the records which were going to be the basis for his preparation of his counter-affidavit were not readily available since the ones in-charged were retrenched quite recently by the corporation due to its continuing financial losses;\par
      \par
      \tab 2.\tab It will be noted that the charges contained in the complaint-affidavit against him refer to various banking transactions which necessitate reference to existing records such as payments made to the bank all these times that Respondent maintained transactions with it.\par
      \par
      \tab 3.\tab This motion is not intended to delay the proceedings but is being filed for the sole purpose stated herein.\par
      \par
      \pard\sl480\slmult1\qc\b PRAYER\par
      \par
      \pard\sl480\slmult1\qj\b0\tab WHEREFORE, in view of the foregoing, Respondent respectfully prays for the above-captioned case to be re-opened and allow schedule a date for the submission of his counter-affidavit. \par
      \par
      \tab Other reliefs just and equitable are likewise prayed for under the premises. \par
      \pard\sl480\slmult1\qc\b EXPLANATION\b0\par
      \pard\sl480\slmult1\qj\par
      \tab The undersigned counsel hereby manifests that he is sending copy of this pleading to the Complainant via registered mail as personal service thereof is impracticable due to distance and time constraints.\par
      \pard\qj\par
      \pard\sl360\slmult1\qj\tab Quezon City for Makati City, December 19, 2007.\par
      \pard\qj\par
      \par
      \par
      \par
      \pard\li4320\qc\ul\f1\fs44 C\fs32 EBALLOS\par
      \pard\li4320\qj\ulnone\f0\fs16                        L A W            F I R M\par
      \fs20\par
      \pard\li4320\qc Counsel for Respondent\par
      \par
      Unit 3E AGCOR Building\par
      335 Katipunan Avenue, Loyola Heights\par
      1108 Quezon City, Metro Manila\par
      \par
      \pard\li4320\qj\fs24 By:\par
      \par
      \pard\li4320\qc\b PONCEVIC M. CEBALLOS\par
      \b0\fs18 PTR NO. 8469122/01-08-07/Quezon City\par
      IBP LRN NO. 02224/01-16-01/Kalookan City\par
      Roll of Attorney No. 33018\par
      \par
      \pard\qj\fs24\par
      Copy Furnished: (via registered mail)\par
      \par
      Atty. Bienvenido D. Comia\par
      Counsel for Petitioner\par
      14 Crimson St., Bonita Homes\par
      Marikina City, Metro Manila\par
      \par
      Construction Industry Arbitration Commission\par
      Jupiter Building, Jupiter Street\par
      Makati City\par
      \par
      Hon. Sedfrey A. Ordonez\par
      Chairman\par
      Construction Industry Arbitration Commission\par
      Jupiter Building, Jupiter Street\par
      Makati City\par
      \pard\sl480\slmult1\qj\par
      \par
      \pard\qc\b\par
      \par
      \par
      }



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