REPUBLIC OF THE PHILIPPINES

FIRST JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 416-A
BAGUIO CITY

RICHIERICH LENDING COMPANY

As represented by its General Manager,
Atty. Jerico G. Rosales, Civil Case No.:
Plaintiff
FOR: Collection of Sum of
Money with Application for
Writ of Preliminary
-versus-
Attachment

Chrsitine E. Karrantez-Hermosa, M.D.,

Defendant
x-----------------------------------------------------x

FORMAL ENTRY OF APPEARANCE WITH MOTION FOR

EXTENSION OF TIME TO FILE AN ANSWER

Undersigned counsel, unto this Honorable Court most

respectfully submits this Formal Entry of Appearance with
Motion for Extension of Time to File an Answer and, in support
thereof, states the following:

FORMAL ENTRY OF APPEARANCE

1. That defendant, Christine E. Karrantez-Hermosa,
only sought the assistance of the undersigned as her
counsel in the above-captioned case in the morning of
August 22, 2019;

2. In this regard, the undersigned counsel most

respectfully enters his appearance as counsel for the
defendant, Christine E. Karrantez-Hermosa.

It is respectfully requested that copies of all Decision,

Orders, Resolutions, Processes issued by the Honorable Court
and pleadings filed by the parties be sent at undersigned
counsel’s address at U533, Albergo Residences, I. Villamor
Drive, Brgy. Lualhati, Baguio City.
 Likewise, with the kind indulgence of this Honorable
Court, the undersigned most respectfully states that:

MOTION FOR EXTENSION OF TIME TO FILE AN ANSWER

3. The last day of the fifteen-day period within which
defendant is permitted to file an Answer, in conformity
with the Rules of Court, is today, August 22, 2019;

4. Because undersigned counsel was just formally

engaged to handle and represent the defendant in the
morning of August 22, 2019, undersigned counsel would
be needing additional time within which to file an Answer
including the collating and studying of records and other
documents pertinent to this case;

WHEREFORE, Defendant, through undersigned counsel,

most humbly and respectfully move for an additional four (4)
day period to be reckoned from the filing of the foregoing, by
way of extension, within which to file and submit the required
ANSWER.
RESPECTFULLY SUBMITTED.

PRAYER
WHEREFORE, premises considered, it is most respectfully
prayed, before this Honorable Court that:
1. The foregoing Formal Entry of Appearance be duly NOTED;
and
2. The Motion for Extension of Time to File An Answer be
GRANTED.

Baguio City, Philippines, August 22, 2019.

HRD LAW FIRM

Collaborating Counsel for the Defendant
U533, Brgy. Lualhati, I. Villamor Drive, Pacdal Circle,
Gibraltar, Baguio City
Contact No.: 09271638704/09123448361
Fax No.: 1622-3550
Email Address: HRD@gmail.com
 By:

ATTY. ROAN JILL E. HABOC

Roll of Attorneys No. 074589
IBP No. 110394; 08-05-2019; Baguio City
PTR No. 2081673; 08-04-2019; Baguio City

COPY FURNISHED:

Atty. Leane Anne G. Barawid

Counsel for the Plaintiff
Roll No. 071895/ 05-02-18
PTR No. 2951538/ 01-15-19/ Baguio City
MCLE No. 12345/ 05-05-19
IBP LIFETIME No. 758252/ 10-03-18
Baguio-Benguet Chapter
Room 301, 3rd Floor, Megatowers and Residences,
Sandico Street, Salud Mitra,
Baguio City, Philippines