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Motion For Extension of Time

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jonah

1) The plaintiff's counsel filed a motion for extension of time to file a reply to the defendant's answer. They were directed to file the reply by March 12, 2020 but need additional time due to a heavy workload and prior scheduled hearings outside Davao City. 2) The motion requests a 15-day extension until March 27, 2020 to submit the plaintiff's reply. 3) The motion is not intended to delay the case but is made necessary by the counsel's reasons stated above. The plaintiff prays that the additional time be granted.

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Motion For Extension of Time

Uploaded by

jonah
493 views2 pages
1) The plaintiff's counsel filed a motion for extension of time to file a reply to the defendant's answer. They were directed to file the reply by March 12, 2020 but need additional time due to a heavy workload and prior scheduled hearings outside Davao City. 2) The motion requests a 15-day extension until March 27, 2020 to submit the plaintiff's reply. 3) The motion is not intended to delay the case but is made necessary by the counsel's reasons stated above. The plaintiff prays that the additional time be granted.

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Motion for extension of time

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1) The plaintiff's counsel filed a motion for extension of time to file a reply to the defendant's answer. They were directed to file the reply by March 12, 2020 but need additional time due to a heavy workload and prior scheduled hearings outside Davao City. 2) The motion requests a 15-day extension until March 27, 2020 to submit the plaintiff's reply. 3) The motion is not intended to delay the case but is made necessary by the counsel's reasons stated above. The plaintiff prays that the additional time be granted.

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

Motion For Extension of Time

Uploaded by

jonah
1) The plaintiff's counsel filed a motion for extension of time to file a reply to the defendant's answer. They were directed to file the reply by March 12, 2020 but need additional time due to a heavy workload and prior scheduled hearings outside Davao City. 2) The motion requests a 15-day extension until March 27, 2020 to submit the plaintiff's reply. 3) The motion is not intended to delay the case but is made necessary by the counsel's reasons stated above. The plaintiff prays that the additional time be granted.

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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


11TH JUDICIAL REGION
Davao City, BRANCH 05

RONALD JOHN A. LAO,


Plaintiff,

- versus - Civil Case No.


For: COLLECTION
OF SUM OF
MONEY
LOURIE MAE CALLOPE,
Defendant.

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

MOTION FOR EXTENSION OF TIME

PLAINTIFF, by counsel, respectfully states that:

1. He has been directed to file a Reply to defendant’s answer by March 12,


2020.

2. The undersigned counsel, however, anticipates her inability to file the


REPLY on or before the said due date because of heavy work load and
prior scheduled hearing outside Davao City. For this reason, the
undersigned is constrained to ask for an additional fifteen (15) days from
March 12, 2020, or until March 27, 2020, within which to submit plaintiff’s
Reply.

3. This motion is not intended for delay but is motivated only by the
foregoing reason.

PRAYER

WHEREFORE, plaintiff respectfully prays that he be granted an


additional fifteen (15) days from March 12, 2020, or until March 27, 2020,
within which to submit plaintiff’s Reply.

1
Davao City, Philippines, March 10, 2020.

Atty. Jonah Margarette F. Presto


Counsel for the Defendant
Presto and Aligato Law Firm
Avocado Building, JP Laurel, Davao City
prestojonahmargarette@gmail.com
Roll No. 64564 issue on 1/3/2017 at Davao City
IBP No. 067990 issued on 5/3/2017 at Davao City
PTR No. 098765 issued on 6/3/2017 at Davao City
MCLE Compliance XI-0013922

Due to the non-litigious character of the foregoing motion, please


submit the same to the Court for its immediate consideration and approval.

Atty. Jonah Margarette F. Presto


Counsel for the Defendant
Presto and Aligato Law Firm
Avocado Building, JP Laurel, Davao City

Copy furnished through personal service:

Atty. Erika Aira De Peralta


Counsel for the Plaintiff
De Peralta Law Firm
Mango Building, Bajada, Davao City

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