Motion For Extension Of Time .docx

Republic of the Philippines FIRST JUDICIAL REGION REGIONAL TRIAL COURT Branch 39, Manila City

ABC CORP. Philippines, Inc. Plaintiff, Civil Case No.: 920813 -versusFor: Specific Performance XYZ Philippines, et al. Defendant. x---------------------------------x

MOTION FOR EXTENSION OF TIME TO FILE ANSWER

PLAINTIFF, by counsel, respectfully states that: (1) We have been required to file a Complaint by 23 March 2019; (2) We, however, have been heavily burdened with Midterms (in Agency under Professor Ryan Oliva and Administrative Law under Professor Michael Tiu) for the past days and have been unable to thoroughly study the Fact Sheets and Contracts in order to prepare an adequate draft for our Complaint. For this reason, the undersigned is constrained to ask for an additional three (3) days from 23 March 2019 within which to submit the Complaint; (3) This motion is not intended for delay but is motivated only by the foregoing reason.

WHEREFORE, plaintiff respectfully prays that he be granted additional three (3) days from 23 March 2019, or until 26 March 2019, within which to submit plaintiff’s Answer.

Manila City, Philippines; 22 March 2019. ATTY. Patricio Espinosa

Counsel for the Plaintiff Palace Building, 36 9th Ave, Bonifacio Global City, Taguig City, Metro Manila, PTR No. 888801; 01/04/2012; Quezon City IBP OR No: 8938291; 01/04/2012; Quezon City Roll No.: 33091; 04/08/2005 Quezon City, Philippines TIN No. 321-897-332-145

NOTICE AND REQUEST

THE CLERK OF COURT RTC Branch 39, Quezon City

ATTY. RAYMONELLE R. REYES REYES & RODOLFO LAW OFFICE Quezon City, Philippines

Greetings! Please note that on 26 March 2019, at nine o’clock in the morning or as soon as the undersigned counsel may be heard, he will submit the foregoing motion for the consideration and approval of the Honorable Court.

ATTY. Patricio Espinosa

Copy Furnished:

ATTY. BALINDONG ROMAN, PARULAN, BALINDONG and JACINTO LAW OFFICE Quezon City, Philippines