Republic of the Philippines

SUPREME COURT

Manila

MOTION WITH LEAVE TO INTERVENE AND TO ADMIT

ATTACHED COMPLAINT-IN-INTERVENTION

Movant-Intervenors, by counsel, to this Honorable Court respectfully states:

This is a Complaint for Declaratory Relief with Prayer for a Writ of Preliminary Injunction and/or Temporary Restraining Order filed on January 2, 2014, to declare Ordinance 7774 prohibiting the admission of customers on a short- time basis or for a short- time rate invalid and unconstitutional.

Herein movants are operators and proprietors of various business establishments in the City of Manila whose main customers are local tourists and people from far- flung areas in the country having their vacation in the Metro.

That the passage of the aforesaid Ordinance will adversely affect herein movant’s lawful occupation and businesses, due to the fact that the establishments they operate are tourist- and people- fueled, and the passage of the Ordinance in controversy may affect the patronage of the movant’s customers.

The passage of the aforesaid Ordinance 7774 will adversely affect the business operation and occupation of movants, to their detriment and prejudice.

WHEREFORE, it is respectfully prayed that an order be rendered admitting herein Movants as Intervenors in the above- entitled case.

Imus City for City of Manila, 7 January 2014.

LOMIBAO LAW OFFICE

406 Violago Homes, Litex, Quezon City

Tel. No. 0917- 8032- 788

Email Add.: ______________________

by:

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IBP No. ___________ ___________ CHAPTER

PTR No. ___________, ___________, ___________

Attorney’s Roll No. ___________

MCLE Compliance No. VI-___________

Notice

HONORABLE SUPREME COURT

City of Manila

Greetings:

Please submit the foregoing motion for the consideration and approval of the Honorable Court immediately upon receipt hereof.

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