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Entry of Appearance

This document is an Entry of Appearance with Motion for Extension of Time to File Answer filed by defendant Rose Soledad T. Sawyer-Tumarao's counsel in a civil case regarding judicial partition. The counsel is entering his appearance on behalf of the defendant and requesting a 15-day extension, until October 5, to file an answer. This is because the counsel was only engaged on September 12 and needs more time to interview witnesses and further study the case. The motion is not intended for delay but to properly handle the case.

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Yohan Agustin
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938 views

Entry of Appearance

This document is an Entry of Appearance with Motion for Extension of Time to File Answer filed by defendant Rose Soledad T. Sawyer-Tumarao's counsel in a civil case regarding judicial partition. The counsel is entering his appearance on behalf of the defendant and requesting a 15-day extension, until October 5, to file an answer. This is because the counsel was only engaged on September 12 and needs more time to interview witnesses and further study the case. The motion is not intended for delay but to properly handle the case.

Uploaded by

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

REGIONAL TRIAL COURT


10th Judicial Region
Malaybalay City, Bukidnon

MAY MADONNA T. SAWYER-GARCIA, Civil Case No. 5176-19


Plaintiff,

-versus-
For:
ROSE SOLEDAD T. SAWYER- JUDICIAL PARTITION
TUMARAO, et al.
Defendants.
X-----------------------------------------------/

ENTRY OF APPEARANCE WITH MOTION FOR


EXTENSION OF TIME TO FILE ANSWER
Defendant Rose Soledad T. Sawyer-Tumarao, through undersigned
counsel, unto this Honorable Court, most respectfully avers that:

1. Undersigned counsel is formally entering his appearance as counsel


for Defendant Rose Soledad T. Sawyer-Tumarao and prays that copies
of pleadings, orders, and other court processes be furnished to him at
his given address;

2. Defendant Sawyer-Tumarao engaged the services of undersigned


counsel only on September 12, 2019;

3. Defendant only received a copy of the Summons and of the Complaint


on September 5, 2019 and has until September 20, 2019 within which
to file an Answer;

4. However, due to equally important professional work and prior


commitments, the undersigned counsel will not be able to meet the
said deadline;

5. As such, undersigned counsel is constrained to request for an


additional fifteen (15) days from the deadline or until October 5, 2019
within which to file an Answer. Moreover, this extension will give the
undersigned counsel ample time to interview the defendant and
available witnesses and study this case further;

6. This motion is not intended for delay but solely for the purpose stated.
2

WHEREFORE, under the premises, undersigned counsel prays for an


extension of time until October 5, 2019 within which to file Defendant’s
Answer.

Other equitable reliefs are likewise prayed for.

Most respectfully submitted.

City of Cagayan de Oro, Philippines for Malaybalay, Bukidnon.


September 13, 2019.

JOHANNE EMMANUEL G. AGUSTIN


Counsel for the Defendant
PTR O/R No. 4096057; 12-19-18(for 2019)
IBP O/R No. 068455; 01-10-19
MCLE No. Pending Processing with IBP
Attorney’s Roll No. 67319

TABOR MORDENO TAN-GAN


SUMICAD-HUERBANA MORDENO
& AGUSTIN LAW OFFICES
2nd Floor Gonzalo Chaves Building,
Tirso Neri corner Capistrano Streets,
Cagayan de Oro City
0917.709.3776

NOTICE OF HEARING

THE BRANCH CLERK OF COURT


RTC
Malaybalay, Bukidnon

ATTY. HOLLIS C. MONSANTO

GREETINGS!

Please take note/kindly submit the foregoing Motion for consideration


and approval of this Honorable Court. Undersigned counsel begs that his
appearance at the hearing be dispensed with as he is submitting the incident
for resolution. Thank you.

JOHANNE EMMANUEL G. AGUSTIN


Copy furnished:
ATTY. HOLLIS C. MONSANTO
2nd Floor Manuel Bldg., San Isidro St.,
Malaybalay City, Bukidnon

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