Motion-for-extension-of-time.docx
This document was uploaded by user and they confirmed that they have the permission to share it. If you are author or own the copyright of this book, please report to us by using this DMCA report form. Report DMCA
Overview
Download & View Motion-for-extension-of-time.docx as PDF for free.
More details
- Words: 331
- Pages: 3
REPUBLIC OF THE PHILIPPINES REGIONAL TRIAL COURT 7TH JUDICIAL REGION BRANCH 1 MANDAUE CITY
PENSHONE INC., plaintiff ARNOLD SY, President
Civil Case No.: 01234
--versus--
For: Specific Performance with Damages
YUNGCHOW CORPORATION, defendant DOMINGO TAN, President
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 26 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 26 March 2019 or until 10 April 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 26 March 2019, or until 10 April 2019, within which to submit plaintiff’s Reply.
Mandaue City; 25 March 2019.
KLAIRE CIARRA G. SANGCO Counsel for the plaintiff Osmena Blvd., Cebu City, Philippines Roll of Attorney No. 66666 IBP Lifetime Membership No. 19484 Cebu City Chapter MCLE No. 5943
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.
KLAIRE CIARRA G. SANGCO 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.
KLAIRE CIARRA G. SANGCO Counsel for the Plaintiff
COPY FURNISHED by registered mail:
Atty. DAHLIA CLAUDINE MAY B. PERRAL Counsel for the Defendant Unit 1234 ABC Building Mandaue City, Cebu
PENSHONE INC., plaintiff ARNOLD SY, President
Civil Case No.: 01234
--versus--
For: Specific Performance with Damages
YUNGCHOW CORPORATION, defendant DOMINGO TAN, President
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 26 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 26 March 2019 or until 10 April 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 26 March 2019, or until 10 April 2019, within which to submit plaintiff’s Reply.
Mandaue City; 25 March 2019.
KLAIRE CIARRA G. SANGCO Counsel for the plaintiff Osmena Blvd., Cebu City, Philippines Roll of Attorney No. 66666 IBP Lifetime Membership No. 19484 Cebu City Chapter MCLE No. 5943
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.
KLAIRE CIARRA G. SANGCO 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.
KLAIRE CIARRA G. SANGCO Counsel for the Plaintiff
COPY FURNISHED by registered mail:
Atty. DAHLIA CLAUDINE MAY B. PERRAL Counsel for the Defendant Unit 1234 ABC Building Mandaue City, Cebu
More Documents from "Gean Pearl Icao"
Ja Complaint Affidavit.docx
April 2020 6
Motion-for-extension-of-time.docx
April 2020 16
Motion-for-extension-of-time.docx
October 2019 25
Answer.docx
October 2019 13
Enroute.docx
October 2019 17