Republic of the Philippines

____________ Judicial Region

________________ TRIAL COURT

Branch _____, _____________, _____________

MOTION FOR BILL OF PARTICULARS

Defendant, by counsel and to this Honorable Court, respectfully states:

1. The complaint alleges that defendant public official, together with herein defendant movant, acting singly or collectively, and or in unlawful concert with one another, in flagrante breach of public trust and of sheer fiduciary obligations as public officers with gross and scandalous abuse of right and power and in brazen violation of the Constitution and laws of the Philippines, embarked upon a systematic plan to accumulate ill-gotten wealth.

2. The foregoing allegations are conclusions of law, which plaintiff should clarify and flesh them with facts and specific acts to enable defendant-movant to prepare and file a responsive answer thereto which requires information as to precise nature, character, scope and extent of plaintiff’s cause of action.

WHEREFORE, defendant prays that plaintiff be ordered to file a bill of particulars of the facts and acts constituting the conclusions alleged in the complaint.

ATTY. _______________________

Counsel for the Defendant

NOTICE OF HEARING

Atty. ______________________

Counsel for the Defendant

Bgy. San Pedro, Puerto Princesa City

Sir:

Please be informed that the undersigned counsel has set the foregoing Motion for Reconsideration for hearing on November 25, 2013 at 8:30 am, for the consideration of the Honorable Court or soon thereafter as counsel maybe heard.

ATTY. ______________________________

Counsel for the Plaintiff

Bgy. Sta. Monica. Puerto Princesa City

AFFIDAVIT OF PERSONAL SERVICE

I, _________________________________, of legal age and having been duly sworn depose and say:

That I am the messenger of Atty. Arnel B. Venturillo, Counsel for the defendant in the case entitled Alexander Bermejo vs. Roel Ponce de Leon, Civil Case No. 65448, and that such messenger I served upon the counsel of adverse party and other parties, the Motion for Consideration filed in said case, as follows:

Atty. Bernardo U. Goy, counsel for the Plaintiff, by personal service by delivering personally copy of said Motion upon said lawyer who acknowledged receipt there of as shown by his signature or initial on the said pleading, this 23^rd day of October 2013

IN WITNESS WHEREOF, I have signed this affidavit this 24^th day of October 2013 at Puerto Princesa City.

_________________________________

Affiant

SUBSCRIBED AND SWORN TO BEFORE ME, A Notary public in and for the City of Puerto Princesa and the Province of Palawan this 24^th day of October 2013. Affiant personally came and appeared with Driver’s License ID No. issued by the Land Transportation Office and valid until May 1, 2015, at Puerto Princesa City, bearing his photograph and signature, known to me as the same person who personally signed the foregoing instrument before me and avowed under penalty of law to the whole truth of the contents of said instrument

_________________________________

Notary Public

Doc. No. ______;

Page No. ______;

Book No. ______;

Series of 20__;

Copy furnished:

____________________________

Counsel for plaintiff

_________________, __________