Motion For Extension: Regional Trial Court

Download as docx, pdf, or txt
Download as docx, pdf, or txt
You are on page 1of 3

REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


NATIONAL CAPITAL JUDICIAL REGION
QUEZON CITY
BRANCH 95

PHILIPPIANS PORT AND


AUXILIARY SERVICES INC.
Plaintiff,
Civil Case No. 18-11973
-versus- For: Specific Performance and
Injunction with Damages
GEORGE F. YAP,
Defendant.
X----------------------------X

MOTION FOR EXTENSION


Defendant GEORGE F. YAP, by counsel, unto this Honorable Court, respectfully
states:

1. Defendant received the summons and the copy of the Complaint on October
09, 2018. Thus, Defendant has until October 24, 2018 within which to file his
Answer;

2. Defendant retained the undersigned as his counsel on October 22, 2018 and
since the Complaint involves actionable documents, the undersigned needs
more time to thoroughly review the said documents;

3. That with the indulgence of this Honorable Court, we hereby pray to grant us
an extension of another fifteen (15) days within which to file the Answer;

4. That this extension is made in good faith and not intended to delay the
proceedings.

1
PRAYER
It is respectfully prayed before this Honorable Court that we be given an
extension of fifteen (15) days within which to file ANSWER.

Other reliefs that are just and equitable are likewise prayed for.

October 23, 2018. Municipality of Iba, Province of Zambales, Philippines.

ATTY. MICHAEL JOSEPH B. LARUTA


Counsel for the Defendant
PTR No. Z 7020955 01/04/18 Subic, Zambales
IBP No. 020431 01/05/2018
MCLE: June 2, 2017 (date of admission to the Phil. Bar)
Roll No. 70366
Capitol Bldg. Zone 5, Iba, Zambales
[email protected]
09072349944/09956106718

2
NOTICE OF HEARING

The Clerk of Court


Regional Trial Court Branch 75
Quezon City, Metro Manila

Greetings: Please take notice that the foregoing Motion shall be submitted for the
consideration and approval of the Honorable Court on November 06, 2018 or as soon
as counsel and matter may be heard.

MICHAEL JOSEPH B. LARUTA

COPY FURNISHED:

PATRON LAW OFFICE


2F ARGO BLDG
574 EDSA cor P. Tuazon Ave.
Cubao, Quezon City, Metro Manila

EXPLANATION
(Pursuant to Section 11, Rule 13 of the 1997 Rules of Civil Procedure)

The foregoing Motion is being served and filed by registered mail due to distance,
which makes personal service impracticable.

You might also like