Republic of the Philippines

FIRST JUDICIAL REGION

REGIONAL TRIAL COURT
Branch 39, Quezon City
FERNANDO A. SAN AGUSTIN,
Plaintiff,
Civil Case No.: 920813
-versusFor: DAMAGES
MANNY L. OTTO,
Defendant.
x---------------------------------x

MOTION FOR EXTENSION OF TIME

PLAINTIFF, by counsel, respectfully states that:
(1) He has been required to file a Reply to defendants Answer by 10 January 2013;
(2) The undersigned counsel, however, anticipates his inability to file the Reply on or before
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 Metro Manila. For this reason, the undersigned is
constrained to ask for an additional fifteen (15) days from 10 May 2013 within which to
submit the plaintiffs 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 additional fifteen (15)
days from 10 January 2013, or until 25 Jnauary 2013, within which to submit plaintiffs Reply.
Quezon City, Philippines; 27 December 2012.

ATTY. GELIE ERIKA P. ESTEBAN

Counsel for the Plaintiff
3F La Azotea Bldg., Session Road, Baguio City

PTR No. 99909; 01/04/2012; Baguio City

IBP OR No: 6928764; 01/04/2012; Baguio City
Roll No.: 81319; 04/08/2005
Baguio City, Philippines
TIN No. 143-444-434-000

NOTICE AND REQUEST

THE CLERK OF COURT
RTC Branch 39, Quezon City
ATTY. REY M. ABANADOR
ABANADOR-LIM LAW OFFFICE
Qeuzon City, Philippines

Greetings!
Please note that on 3 January 2013, at 8:30 oclock 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. GELIE ERIKA P. ESTEBAN

Copy Furnished:
ATTY. REY M. ABANADOR
ABANADOR-LIM LAW OFFFICE
Qeuzon City, Philippines
Pg136