Republic of the Philippines

____________ Judicial Region

________________ TRIAL COURT

Branch _____, _____________, _____________

MOTION TO EXERCISE VISITATION RIGHTS OF PETITIONER

Petitioner, by counsel, to this Honorable Court respectfully states:

Since separation de facto of herein parties, petitioner has not seen nor meet KATHRINE BERNARDO CORONADO, his daughter with herein respondent. Petitioner’s daughter has been in the custody of respondent ever since he decided to pack his things and leave the conjugal abode in December 2003 due to unbearable circumstances.

Efforts to visit his daughter proved exceedingly difficult if not almost impossible on the part of the petitioner due to herein parties’ personal animosity.

Since the separation de facto of herein parties, petitioner has continued to support to his daughter by depositing the money in the account of the respondent.

Petitioner wishes to exercise his visitation rights over his daughter. Henceforth, petitioner proposed to pick up her daughter every other Saturday every month in the mall or residence of the respondent or any other place designated or agreed upon by herein parties to be returned on the same day or the next day as agreed upon by both parties.

PRAYER

WHEREFORE, it is respectfully prayed that after due notice and hearing, an order by this Honorable Court enforcing the visitation right over his daughter be issued in favor of the petitioner.

Imus City, for Pasay City, January 9, 2014.

LOMIBAO LAW OFFICE

406 Violago Homes, Litex, Quezon City

Tel. No. 0917- 8032- 788

Email Add.: ________________________

by:

____________________________________

IBP No. ____________ ____________ CHAPTER

PTR No. ____________, ____________, ____________

Attorney’s Roll No. ____________

MCLE Compliance No. VI-____________

Notice

THE CLERK OF COURT

RTC Branch 113

Pasay City

HON. SOLICITOR GENERAL

134 Amorsolo St., Amorsolo Bldg.,

Legaspi Village, Makati City

OFFICE OF THE CITY PROSECUTOR

Pasay City

ELLEN A. ADARNA

316 Palin St., Block 27 Lot 77

Ai- Ai, General Tinio, GMA, Cavite

Greetings:

Please take notice that on Tuesday, 21 May 2013 at 3:00 o clock in the afternoon, or as soon as counsel may be heard, undersigned shall submit the foregoing urgent motion for the consideration and approval of this Honorable Court.

RICA KAYE O. LOMIBAO

Copy furnished:

HON. SOLICITOR GENERAL

134 Amorsolo St., Amorsolo Bldg.,

Legaspi Village, Makati City

OFFICE OF THE CITY PROSECUTOR

Pasay City

ELLEN A. ADARNA

316 Palin St., Block 27 Lot 77

Ai- Ai, General Tinio, GMA, Cavite

Explanation

The foregoing motion is being filed to the Honorable Court with copy therefore furnished to the Office of the Solicitor General, Office of the Provincial Prosecutor and to the other party by registered mails, due to the distance of the undersigned from the said office and other party, making personal service thereof not practicable.

RICA KAYE O. LOMIBAO