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    Motion For Extention of Time

    Uploaded by

    CloieRj
    This document is a Motion for Extension of Time to File Answer filed in the Regional Trial Court-Branch 24 in Maasin City, Southern Leyte, Philippines. The defendant's counsel is requesting a 15 day extension to file the Answer or Responsive Pleading in the civil case of Juana de la Cruz vs. Cruz D. Juan for breach of contract of carriage. Counsel states that she was only engaged on March 11, 2019 and needs additional time to interview witnesses and further study the case due to other professional commitments. The motion is not intended for delay but to allow sufficient time to properly respond to the Complaint.

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    Motion For Extention of Time

    Uploaded by

    CloieRj
    164 views2 pages
    This document is a Motion for Extension of Time to File Answer filed in the Regional Trial Court-Branch 24 in Maasin City, Southern Leyte, Philippines. The defendant's counsel is requesting a 15 day extension to file the Answer or Responsive Pleading in the civil case of Juana de la Cruz vs. Cruz D. Juan for breach of contract of carriage. Counsel states that she was only engaged on March 11, 2019 and needs additional time to interview witnesses and further study the case due to other professional commitments. The motion is not intended for delay but to allow sufficient time to properly respond to the Complaint.

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    1. motion for extention of time

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    This document is a Motion for Extension of Time to File Answer filed in the Regional Trial Court-Branch 24 in Maasin City, Southern Leyte, Philippines. The defendant's counsel is requesting a 15 day extension to file the Answer or Responsive Pleading in the civil case of Juana de la Cruz vs. Cruz D. Juan for breach of contract of carriage. Counsel states that she was only engaged on March 11, 2019 and needs additional time to interview witnesses and further study the case due to other professional commitments. The motion is not intended for delay but to allow sufficient time to properly respond to the Complaint.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    164 views2 pages

    Motion For Extention of Time

    Uploaded by

    CloieRj
    This document is a Motion for Extension of Time to File Answer filed in the Regional Trial Court-Branch 24 in Maasin City, Southern Leyte, Philippines. The defendant's counsel is requesting a 15 day extension to file the Answer or Responsive Pleading in the civil case of Juana de la Cruz vs. Cruz D. Juan for breach of contract of carriage. Counsel states that she was only engaged on March 11, 2019 and needs additional time to interview witnesses and further study the case due to other professional commitments. The motion is not intended for delay but to allow sufficient time to properly respond to the Complaint.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 2

    Republic of the Philippines

    SUPREME COURT
    Eighth (8th) Judicial Region
    Regional Trial Court-Branch 24
    Bulwagan ng Katarungan
    Maasin City, Southern Leyte

    JUANA de la CRUZ, CIVIL CASE No. 128967


    Plaintiff, FOR: BREACH OF CONTRACT OF
    CARRIAGE (ART. 1733 in relation to
    Art 1755, etc., New Civil Code of the
    -versus- Philippines) WITH DAMAGES

    CRUZ D. JUAN,
    Defendants.
    x---------------------------------------------x

    MOTION FOR EXTENSION OF TIME TO


    FILE ANSWER
    DEFENDANT, by the undersigned counsel, and unto this
    Honorable Court, most respectfully states that:

    1. Defendant engaged the services of undersigned counsel only on


    March 11, 2019;

    2. Defendant was served with Summons and copy of the


    Complaint on November 24, 2019 and thus has until December
    11, 2019 within which to submit an Answer or Responsive
    Pleading;

    3. However, due to the pressures of equally urgent professional


    work and prior commitments, the undersigned counsel will not
    be able to meet the said deadline to file answer;

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


    additional period of 15 days from today
    within which to submit Defendant's Answer or Responsive
    Pleading. Moreover, this additional time will also allow the
    undersigned to interview the available witness and study this
    case further;
    5. This Motion is not intended for delay but solely due to the
    foregoing reasons.
    PRAYER

    WHEREFORE, Defendant most respectfully prays of this


    Honorable Court that he be given an additional period of 15 days
    from today within which to submit an Answer or other Responsive
    Pleading.
    Other relief just and equitable are likewise prayed for.
    Maasin City, Southern Leyte, Philippines, November 24,2019.

    ATTY. CLOIE ANNE C. SULLA


    Attys. Roll No. 51444/ 5-10-06
    PTR No. 9005803/1-4-20 Maasin City
    IBP O.R. NO. 0989528/01-04-20, Southern Leyte Chapter
    MCLE COMPLIANCE NO.: V-0004454/11-12-2014 valid
    until 11-12-2020

    NOTICE

    Atty. Ace Vincent Gertos


    Branch Clerk of Court
    &
    Atty. Jackielyne C. Gaviola
    Counsels for the Plaintiff

    Please take notice that this motion will be submitted for the
    resolution of the Honorable Presiding Judge immediately upon filing
    hereof appearance and oral arguments from parties and counsels.

    Atty. CLOIE ANNE C. SULLA

    Copy furnished:

    ATTY. Jackielyne C. Gaviola


    Counsel for the Plaintiff
    2233 Brgy. Combado, Maasin City, Southern Leyte

    Please take notice that counsel has requested for the approval
    of this motion immediately upon receipt.

    Atty. Cloie Anne C. Sulla

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