Republic of the Philippines

REGIONAL TRIAL COURT

7th Judicial Region
Branch 54
Lapu-Lapu City

HOPE A. MADRID
Plaintiff
Civil Case No: 5959-L
-versus- For: BREACH OF CONTRACT
WITH
DAMAGES

FAIR T. JARVIS
Defendant
x- - - - - - - - - - - - - - - - - - - - - - - - x

MOTION FOR EXTENSION OF TIME TO FILE ANSWER

COMES NOW, the Defendant, FAIR T. JARVIS, by the undersigned

Counsel, and unto the Honorable Court most respectfully avers:

1. That the services of the services of the undersigned counsel was only
engaged by Defendant only yesterday, August 3, 2018;

2. That today is the deadline for the Defendant, Fair T. Jarvis, to submit
the Answer;

3. That due to heavy pressures of work, preparation of pleadings and

previous court commitments from another equally and urgent cases
that beset the undersigned counsel, the latter could not submit the
Answer on time;

4. That in the light of the foregoing predicament, undersigned counsel,

respectfully request the kind consideration and indulgence of this
Honorable Office, to give herein Defendant another ten (10) days
from today to submit the Answer or until August 13, 2018; and

5. That this motion is filed in good faith and is not intended to delay the
proceedings of this Honorable Office, but solely impelled by the
foregoing circumstances.

PRAYER

WHEREFORE, it is most respectfully prayed of this Honorable

Office to give herein Defendant another ten (10) days from today to
submit the Answer or until August 13, 2018.

1
 Respectfully submitted. Lapu-Lapu City, Cebu. August 3, 2018.

TIM GO WAN LAW OFFICES

Counsel for Defendant
Room 101, Horizon Bldg., Pusok, Lapu-Lapu City
E-mail: timhowan@gmail.com
Contact No: (032) 4148928

BY:

ATTY. CAROLINE MARIE M. GO, CPA

Roll of Attorneys No. 65825
IBP O.R. No. 1019991/01-05-2018/Cebu
PTR O.R. No. 5121992/01-04-2018/Lapu-Lapu City
MCLE Compliance No. V-0013440 valid until 2019

REQUEST/SUBMISSION FOR HEARING

The Branch Clerk of Court

RTC Branch 54
Hall of Justice
Pusok, Lapu-Lapu City

Please submit the foregoing Motion to the Court for its consideration and
approval upon receipt hereof and kindly include the same in the court's
calendar for hearing on August 10, 2018, Friday at 9:00am.

NOTICE FOR HEARING

HOPE A. MADRID
Babag II, Cordova, Cebu

Please take notice that counsel has requested to be heard on August 10,
2018, Friday at 9:00am.

ATTY. CAROLINE MARIE M. GO, CPA

Copy furnished: HOPE A. MADRID

Bagbag II, Cordova, Cebu