REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

SEVENTH JUDICIAL REGION
BRANCH 22
CEBU CITY

PENSHONE INC., herein

represented by Minsi Thar in
his capacity as the President
of Penshone Inc.,
Plaintiffs,

CIVIL CASE NO. 123-A1

- versus - For: Collection for a Sum
of Money, Damages,
Attorney’s Fees

YUNGCHOW CORPORATION,
herein represented by Zi Long
in his capacity as the
President of Yungchow
Corporation and Chou King in
his capacity as head of the
Purchasing and Accounting
Department of Yungchow
Corporation,
Defendants.
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MOTION FOR EXTENSION OF TIME

TO FILE ANSWER

DEFENDANTS, by counsel, respectfully state:

 1. The Honorable Court issued Summons to defendants
requiring them to file within fifteen (15) days from receipt
thereof their Answer to the complaint. Defendants received the
Summons on 08 February 2019. Thus, defendants have until
23 February 2019 within which to file their Answer.

2. The services of the undersigned counsel, however,

have only been recently engaged by the defendants. Considering
the nature of the case and the fact that undersigned counsel
also has other equally important cases to attend to,
undersigned counsel needs sufficient time to confer with his
clients and the witnesses and to study the case to enable him
to intelligently prepare his clients’ defense.

3. Thus, defendants are constrained and hereby beg the

kind indulgence of the Honorable Court that they be granted
fifteen (15) days from 23 February 2019 or until 10 March 2019,
to submit their Answer to the complaint.

4. This motion is filed in utmost good faith and is not

intended to delay the proceedings in the above-captioned case.

PRAYER

WHEREFORE, it is respectfully prayed of the Honorable

Court to GRANT herein defendants fifteen (15) days from 23
February 2019, or until 10 March 2019, to submit their Answer
to the complaint.

Other reliefs, just and equitable under the premises, are

likewise prayed for.

RESPECTFULLY SUBMITTED.
Cebu City, Philippines, 18 February 2019.
 Atty. MARLON C. BALTAR
Counsel
Roll of Attorney No. 12345
IBP Member No. 199384, 05-19-17
PTR No.: 12345, 01-09-19, Cebu City
MCLE Compliance No. D-987642, 03-09-18