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Republic of The Philippines: Regional Trial Court

The defendant's counsel filed a Motion for Extension of Time with the Regional Trial Court of Cebu City, Branch 18. In the motion, the counsel requests a 10-day extension to file an Answer to the Complaint, as the counsel has other urgent work and commitments that prevent filing within the original 15-day deadline. The counsel asserts this extension is needed to properly review the Complaint and is not intended to delay the case. The motion includes a Notice of Hearing stating the motion will be submitted without a hearing, and an Explanation of why service was done by registered mail instead of in person.

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John Paul Jaen
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36 views

Republic of The Philippines: Regional Trial Court

The defendant's counsel filed a Motion for Extension of Time with the Regional Trial Court of Cebu City, Branch 18. In the motion, the counsel requests a 10-day extension to file an Answer to the Complaint, as the counsel has other urgent work and commitments that prevent filing within the original 15-day deadline. The counsel asserts this extension is needed to properly review the Complaint and is not intended to delay the case. The motion includes a Notice of Hearing stating the motion will be submitted without a hearing, and an Explanation of why service was done by registered mail instead of in person.

Uploaded by

John Paul Jaen
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

REGIONAL TRIAL COURT


7th Judicial Region
Branch 18
Cebu City

PENSHONE INC, CIVIL CASE NO.:


Plaintiff,
.

-versus-

YUNCHOW CORPORATION,
Defendants.
x-------------------------------------------------x

MOTION FOR EXTENSION OF TIME

COMES NOW,DEFENDANTS, through the undersigned


counsel, and unto this Honorable Court, most humbly and
respectfully avers that:

1. That defendant through counsel have in open court been


ordered to file an answer to the complaint of herein plaintiff
within fifteen (15) days;

2. However, due to the pressures of equally urgent


professional work and prior commitments, the undersigned
counsel will not be able to meet the said deadline;

3. As such, undersigned counsel is constrained to request for


an additional period of ten (10) days from today within
which to submit Defendant's Answer or Responsive
Pleading. Moreover, this additional time will also allow the
undersigned to review the COMPLAINTof herein
complainant;

4. This Motion is not intended for delay but solely due to the
foregoing reasons.

PRAYER

1
WHEREFORE, Defendant most respectfully prays of this
Honorable Court that he be given an additional period of ten (10)
days from today within which to submit an Answer or other
Responsive Pleading.

Other relief just and equitable are likewise prayed for.


City of Cebu, Philippines, 6th of March 2019.

JAEN Law
Counsel for the Defendant
3083 V.RAMA GUADALUPE CEBU CITY
Contact No. (032)-222-3333
Email: [email protected]

By:

ATTY. JOHN PAUL JAEN


Roll No. 000333. Admitted at Bar: JANUARY, 2016
IBP # 6693
PTR No. 0002222, Cebu City

NOTICE OF HEARING

Atty. DARRYL VIDAD


Counsel for the Plaintiff
3RD FLOOR Ayala Building.

2
Osmeña Blvd., Cebu City

Greetings: Please take notice that the foregoing Motion for


Extension to File Answer shall be submitted for the consideration and
approval of the Honorable Court sans hearing.

ATTY. JOHN PAUL JAEN

EXPLANATION

The foregoing Motion is being filed with this Honorable Court


and served on the opposing counsel by registered mail in view of the
impracticability of personal filing and service due to distance.

ATTY. JOHN PAUL JAEN

COPY FURNISHED:

Atty. DARRYL VIDAD


Counsel for the Plaintiff
3RD FLOOR Ayala Building.

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