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Motion Montereal

The defendant filed a Motion for Extension of Time to File an Answer in a civil case. They were originally given 15 days from service of the summons to submit their Answer, which was September 6, 2019. However, they request an additional 15 days, until September 21, 2019, to gather documents and witness testimonies to incorporate into their Answer. They served the motion by registered mail due to time, distance, and manpower constraints.

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King Monteclaro Montereal
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100 views4 pages

Motion Montereal

The defendant filed a Motion for Extension of Time to File an Answer in a civil case. They were originally given 15 days from service of the summons to submit their Answer, which was September 6, 2019. However, they request an additional 15 days, until September 21, 2019, to gather documents and witness testimonies to incorporate into their Answer. They served the motion by registered mail due to time, distance, and manpower constraints.

Uploaded by

King Monteclaro Montereal
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


1st JUDICIAL REGION
BRANCH 416B
BAGUIO CITY

PROF E. SSOR, Civil Case No. _____


Plaintiff, For: Collection of Sum of
Money with Prayer of writ
-versus- for the issuance of
Preliminary Attachment
DO C. TOR,
Defendant.

x---------------------------------------------x

MOTION FOR EXTENSION OF TIME TO


FILE AN ANSWER

Defendant to the Honorable Court most respectfully state:

1. That he was given by the Honorable Court to submit his Answer in


the above-titled case fifteen (15) days from service of the summons or until
September 6, 2019;

2. As he is still in the process of gathering evidence including


documents and testimonies of witnesses to be incorporated to his Answer.
They request that they be given additional fifteen days or until September 21,
2019 to submit the Answer

PRAYER

WHEREFORE, defendant most respectfully pray that the Honorable


Court GRANTS this Motion and give the defendant additional fifteen days or
until September 21, 2019 to submit his Answer and supporting documents, if
any.
Other reliefs which are just and equitable in the premises are also prayed
for.

Baguio City, Philippines. August 22, 2019.

DEFEND AND ASSOCIATES


Counsel for the Defendant
#02 Upper Session Rd., Baguio City
Tel. No. 420-0000 | e-mail: defendandassociates@gmail.com

ATTY. DEFEND D. POOR


#2 Upper Session Rd., Baguio City
Roll No. 111111
IBP No. 01111111/June 13, 2018
Baguio-Benguet Chapter
PTR No. 1111111/June 06, 2019
MCLE Certificate of Compliance No. 2222222
NOTICE OF HEARING

THE BRANCH CLERK OF COURT


RTC - Branch 416B
Baguio City

Greetings!

Kindly submit the foregoing motion for consideration and approval of


this Honorable Court immediately upon receipt hereof.

ATTY. DEFEND D. POOR


#2 Upper Session Rd., Baguio City
Roll No. 111111
IBP No. 01111111/June 13, 2018
Baguio-Benguet Chapter
PTR No. 1111111/June 06, 2019
MCLE Certificate of Compliance No. 2222222

Copy furnished:

HON. JUDGE GLENDA SORIANO


Presiding Judge
Regional Trial Court
Branch 416B, Baguio City

ATTY. KING ANTHONY M. MONTEREAL


Counsel for the Petitioner
DMO Law Office
#1 Upper Session Rd., Baguio City

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

ATTY. DEFEND D. POOR


#2 Upper Session Rd., Baguio City
Roll No. 111111
IBP No. 01111111/June 13, 2018
Baguio-Benguet Chapter
PTR No. 1111111/June 06, 2019
MCLE Certificate of Compliance No. 2222222
EXPLANATION
(Pursuant to Section 5, 7, & 11 Rule 13, 1997 Rules of Civil Procedure)

The foregoing Motion For Extension of Time is served by registered mail


as personal service is not practical because of time, distance and manpower
constraints.

ATTY. DEFEND D. POOR


#2 Upper Session Rd., Baguio City
Roll No. 111111
IBP No. 01111111/June 13, 2018
Baguio-Benguet Chapter
PTR No. 1111111/June 06, 2019
MCLE Certificate of Compliance No. 2222222

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