Republic of the Philippines
MOVIE & TELEVISION REVIEW AND CLASSIFICATION BOARD
MTRCB Bldg., No. 18, Timog Ave., Quezon City
MS. ELEONOR L. CARDONA,
MTRCB ADMIN. CASE NO. 023-2010
- versus -
“CUTTING EDGE” TV PROGRAM and SKY CABLE CHANNEL 28 OF DAVAO
CITY OPERATED BY SUNCABLE
SYSTEMS DAVAO, INC.,
URGENT MOTION FOR POSTPONEMENT AND EXTENSION OF TIME
TO SUBMIT RESPONDENT’S COUNTER-AFFIDAVIT
COME NOW, respondent “CUTTING EDGE” TV PROGRAM, represented by Pastor John J. Feeney, through undersigned counsel, before this Honorable Board, most respectfully avers that:
Respondent received the SUMMONS AND NOTICE OF HEARING on July 13, 2010;
Hence, respondent has seven (7) days or until July 20, 2010 within which to submit their counter-affidavits;
However, respondent failed to submit said counter-affidavit within the period given for lack of material time to prepare said counter-affidavit as respondent still had to procure the services of a lawyer to prepare his counter-affidavit;
Upon referral of the matter to undersigned counsel and on account of his heavy workload and urgent commitments, he will not be able to prepare and submit the counter-affidavit;
In view of the foregoing, undersigned counsel would like to humbly request the Honorable Commission to grant the respondent an opportunity to submit a counter-affidavit on or before August 13, 2010;
Furthermore, respondent prays, on the grounds of justice and equity, for a postponement of the hearing set on July 29, 2010 at 2:00 in the afternoon, to a later date preferably on August 28, 2010;
This Motion is filed in good faith and not to unduly delay the proceedings of this case.
WHEREFORE, respondent Pastor John J. Feeney is praying to allow him to submit his counter-affidavit on or before August 13, 2010.
Furthermore, respondent prays that the hearing set on July 29, 2010 at 2:00 in the afternoon be postponed to later date preferably on August 28, 2010.
All other reliefs just and equitable under the circumstances are likewise prayed for.
July 28, 2010 at Davao City (for Quezon City), Philippines.
ATTY. PHILIP JOHN L. POJAS
Counsel for Respondent “CUTTING EDGE” TV PROGRAM
Roll of Attorneys No. 54869
PTR No. 8442931/January 04, 2010/Davao City
IBP No. 784563/ January 04, 2010/Davao City
MCLE Cert. No. III-0014115
Office Address: 791-3 Mitsui Bussan Street,
Bajada, Davao City
ATTY. CHARLEMAGNE B. ALDEVERRA Received: __________________
Counsel for Complainant Date: _____________________
Room 201 and 206, 2/F,
Davao Consultants Center,
Sandawa Plaza, Matina,
NOTICE OF SUBMISSION
MOVIE & TELEVISION REVIEW
AND CLASSIFICATION BOARD
MTRCB Bldg., No. 18, Timog Ave.,
ATTY. CHARLEMAGNE B. ALDEVERRA
Counsel for Complainant
Undersigned counsel would like to submit this Motion to the discretion of the Honorable Board without further appearance by said counsel.
ATTY. PHILIP JOHN POJAS
EXPLANATION OF FILING AND SERVICE
A Motion has been filed before this Honorable Board and copies served upon opposing counsel by registered mail for lack of material time and messengerial service to effect personal service.
ATTY. PHILIP JOHN POJAS