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REPUBLIC OF THE PHILIPPINES

CALABARZON JUDICIAL REGION


Regional Trial Court
Lipa City - Branch 13

JUAN DELA CRUZ, Civil Case No. 10- 23346- 15


Complainant,
-versus-
SAM GARCIA
Respondents,
x-----------------------------------------------------x
MOTION FOR EXTENSION OF TIME

DEFENDANT, by the undersigned counsel, and unto this Honorable Court,


most respectfully states that:
1. Defendant engaged the services of undersigned counsel only on April 13,
2018;
2. Defendant was served with Summons and copy of the Complaint on April 10,
2018 and thus has until April 20, 2018 within which to submit an Answer or
Responsive Pleading;
3. However, due to the pressures of equally urgent professional work and prior
commitments, the undersigned counsel will not be able to meet the said
deadline;
4. As such, undersigned counsel is constrained to request for an additional
period of 5 days from today within which to submit Defendant's Answer or
Responsive Pleading. Moreover, this additional time will also allow the
undersigned to interview the available witness and study this case further;

5. This Motion is not intended for delay but solely due to the foregoing reasons.

PRAYER
WHEREFORE, Defendant most respectfully prays of this Honorable Court that
he be given an additional period of 15 days from today within which to submit
an Answer or other Responsive Pleading.

Other relief just and equitable are likewise prayed for.

Lipa City, Batangas, Philippines, 14, April 2018.

ATTY. ALEXANDRA P. ABITAN


Notary Public for Lipa City Abitan Law Firm
3F MGM Building J.P. Laurel Highway,
Mataas na Lupa, Lipa City,
Philippines Attorney’s Roll No. 56789
IBP No. 876543 -01/04/18 – Lipa City
PTR No. 008765 -01/05/18 – Lipa City
MCLE Compliance No. I-0008776 – Feb. 5, 2018

COPY FURNISHED: OPPOSING COUNSEL