Motion-for-extension-of-time.docx
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REPUBLIC OF THE PHILIPPINES REGIONAL TRIAL COURT 7TH JUDICIAL REGION BRANCH 1 MANDAUE CITY
PENSHONE INCORPORATED, Through Mr. Noah Santos in his Capacity as Company Sales Manager, Plaintiff CIVIL CASE NO. ____________ FOR: Specific Performance With Damages
-versus-
YUNGCHOW CORPORATION, Mr. Yung Chow and Zhen Zhu Chiu Defendant, x------------------------------------x MOTION FOR EXTENSTION OF TIME TO FILE A REPLY Plaintiff, by counsel, respectfully states that: 1. He has been directed to file a Reply to defendant’s Answer by 15 March 2019. 2. The undersigned counsel, however, anticipates his inability to file the Reply on or before the said due date because of the tremendous pressure of other equally urgent professional work requiring the preparation of pleadings and almost daily trial appearances before the various courts within and outside Cebu Province. For this reason, the undersigned is constrained to ask for an additional fifteen (15) days from 15 March 2019 or until 30 March 2019, within which to submit Plaintiff’s Reply. 3. This motion is not intended for delay but is motivated only by the foregoing reason.
WHEREFORE, plaintiff respectfully prays that he be granted an additional fifteen (15) days from 15 March 2019 or until 30 March 2019, within which to submit plaintiff’s Reply.
Mandaue City; 14 March 2019.
GEAN PEARL PAO ICAO Counsel of the Plaintiff Roll of Attorney No. 19930718 IBP Lifetime Member No. 7018 Cebu City PTR No. 239612 01/03/2019 Cebu City MCLE Compliance No.98322
NOTICE OF HEARING
The Clerk of Court Regional Trial Court City of Mandaue Branch 1 Greetings: Kindly submit the foregoing motion for the consideration and approval of the Honorable Court immediately upon your receipt hereof. GEAN PEARL ICAO Counsel for the Plaintiff
EXPLANATION Undersigned counsel for the Plaintiff has furnished the counsel of the defendant a copy of the foregoing motion through registered mail, and not by personal delivery, because of distance and time constraint. GEAN PEARL PAO ICAO Counsel for the Plaintiff
COPY FURNISHED by registered mail:
Atty. JASON MOMOA Counsel for the Defendant Unit 1234 ABC Building Mandaue City, Cebu
PENSHONE INCORPORATED, Through Mr. Noah Santos in his Capacity as Company Sales Manager, Plaintiff CIVIL CASE NO. ____________ FOR: Specific Performance With Damages
-versus-
YUNGCHOW CORPORATION, Mr. Yung Chow and Zhen Zhu Chiu Defendant, x------------------------------------x MOTION FOR EXTENSTION OF TIME TO FILE A REPLY Plaintiff, by counsel, respectfully states that: 1. He has been directed to file a Reply to defendant’s Answer by 15 March 2019. 2. The undersigned counsel, however, anticipates his inability to file the Reply on or before the said due date because of the tremendous pressure of other equally urgent professional work requiring the preparation of pleadings and almost daily trial appearances before the various courts within and outside Cebu Province. For this reason, the undersigned is constrained to ask for an additional fifteen (15) days from 15 March 2019 or until 30 March 2019, within which to submit Plaintiff’s Reply. 3. This motion is not intended for delay but is motivated only by the foregoing reason.
WHEREFORE, plaintiff respectfully prays that he be granted an additional fifteen (15) days from 15 March 2019 or until 30 March 2019, within which to submit plaintiff’s Reply.
Mandaue City; 14 March 2019.
GEAN PEARL PAO ICAO Counsel of the Plaintiff Roll of Attorney No. 19930718 IBP Lifetime Member No. 7018 Cebu City PTR No. 239612 01/03/2019 Cebu City MCLE Compliance No.98322
NOTICE OF HEARING
The Clerk of Court Regional Trial Court City of Mandaue Branch 1 Greetings: Kindly submit the foregoing motion for the consideration and approval of the Honorable Court immediately upon your receipt hereof. GEAN PEARL ICAO Counsel for the Plaintiff
EXPLANATION Undersigned counsel for the Plaintiff has furnished the counsel of the defendant a copy of the foregoing motion through registered mail, and not by personal delivery, because of distance and time constraint. GEAN PEARL PAO ICAO Counsel for the Plaintiff
COPY FURNISHED by registered mail:
Atty. JASON MOMOA Counsel for the Defendant Unit 1234 ABC Building Mandaue City, Cebu
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