ANALYSIS OF 11/5/2015 EX-PARTE MOTION TO SET CASE FOR PRE-TRIAL AND ORDER

Enough is enough, and we are finally able to motion to set the case for pre-trial. An actual trial is a long way off, but hopefully we will get there eventually.

Also note that the previous judge has just retired and we have a new judge. Maybe it was her time, or just maybe she was a little tired of all the baseless motions that are sure to continue. We will never know. Anyway, the new judge approved of the motion and set the case for pre-trial.

. ... ,., -�·

JULIAN COHEN,

Plaintiff,

- versus -

MOTOR IMAGE PILIPINAS, INC., MR. BENEDICTO G. ARCINAS, LAUS MARKETING CORPORATION, AUTOSALES & AFTERSALES CO. INC.,

Defendants. x-------------------------------------------)

CIVIL CASE NO. 73836

For: Breach of Contract and Damages

EX-P ARTE MOTION TO SET CAS

PRE-TRIAL

Plaintiff JULIAN COHEN, through the undersigned counsel, most respectfully states;

1. On 26 October 2015, Plaintiff received the Order dated 16October 2015, which denied Defendants' Motion for Reconsideration dated 29 June 2015.

2. Considering that Defendants have already filed theirAnswer to the Second Amended Complaint and the issues are now joined, Plaintiff hereby moves that the case be set for pre-trial pursuant to Section 1, Rule 18 of the Rules of Court.

PRAYER

WHEREFORE, premises considered, Plaintiff respectfully prays that the case be set for pre-trial on 07 January 2016 at 8:30AM or on dates that the calendar of the Honorable Court permits.

Other just and equitable reliefs are likewise prayed for.

Cohen vs. Matar Image

Ex-Parte Motion to Set Case for Pre-TrialX ---------�

-2-

Makati City for Pasig City: 05 November 2015.

By:

PARAS & MANLAP AZ

Lawyers Counsel for Plaintiff

1402 BDO Equitable Tower 8751 Paseo de Roxas, Makati City

Tel No. 817-3484; Fax No. 817-3508 Email: lawyers@parasmanlapazlawyers.com

SIDDHARTA JP III S. PEN AREDONDO Lifetime IBP No. 03265/1-7-04/Iloilo City PTR No. 4753775/1-7-2015/Makati City

Roll No. 46728 MCLE Compliance No. IV- 9197 /4-26-2013

EMMAN E P. CRUZ

IBP No. 0999554/10-Mar-15/Makati City PTR No. 4997254/30-Jul-15/Makati City

Roll No. 62611 MCLE Compliance No. Admitted 2013

NOTICE & REQUEST

The Branch Clerk of Court Regional Trial Court Branch 160, San Juan City

Kindly submit the foregoing Ex-Parte Motion to Set Case for Pre­Trial for consideration and resolution of the Honorable Court upon receipt hereof.

Atty. RAMIL G. AUSTRIA Counsel for MIPI & Mr.Benedicto Arcinas ARCINAS & ARCINAS 2K Edificio Enriqueta

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