REPUBLIC OF THE PHIPIPPINES

First Judicial Region

Regional Trial Court
Baguio City, Branch___

Professor Baguio, Civil case no. ___

Plaintiff, For: Collection of

sum of money
--versus--

Doctor Benguet,
Defendant,

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MOTION FOR EXTENTSION OF TIME TO FILE ANSWER

Defendant through the undersigned counsel unto the

Honorable Court respectfully states that:

1. On August 28, 2018, defendant received a summons

issued by the Honorable Court requiring them to file
their Answer in the above-entitled case within fifteen
(15) days from receipt of the said summons. Thus,
defendants have up to September 13, 2018 within
which to file the required Answer;
2. While the undersigned counsel has already started
with the preparation of the Defendants’ Answer, he
foresees the impossibility of finalizing the same on its
due date for the reason that he is still collating the
documents submitted to him by the corporation
which are to be attached to the Answer;
 3. This is also coupled with the fact that the
undersigned counsel is predisposed with daily court
appearances during the past weeks for which reason
he was not able to devote sufficient time to finalize
the defendants’ Answer,
4. In view of the foregoing, the defendant begs the
indulgence of the Honorable Court to grant them an
additional period of eleven (11) days from September
13, 2018 until September 24, 2018 to file his Answer;
5. This motion is not intended to delay the proceedings
but only for the reasons so stated

WHEREFORE, all premises duly considered, it is respectfully

prayed unto the Honorable Court to grant defendant and
additional eleven (11) days reckoned from September 13,
2018 or until September 24, 2018 within which to file his
Answer

Other reliefs just and equitable in the premises are likewise

prayed for, Baguio City, Philippines, September 14, 2018.

MIKAEL LORENZO TABANDA

Counsel for the Defendant

2nd floor Lapeeral Building, Session rd

Baguio City

Roll No.

PTR No.
 IBP No.

MCLE Compliance No.

NOTICE of HEARING and COPY FURNISHED

TO: THE Branch Clerk of Court

Regional Trail Court

Baguio City, Branch 60

Mr. Professor Baguio

Atty. Of Professor Baguio