REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT IN CITIES

City of Iloilo
Branch 2

CHRISTIAN TIDONG,
Plaintiff,
-versus-

CIVIL CASE NO. 14344

CARL DEITA,
Defendant.
x--------------------------------------------x

MOTION FOR EXTENSION OF TIME TO FILE ANSWER

DEFENDANT, by the undersigned counsel, and unto this
Honorable Court, most respectfully states that:
1. Defendant engaged the services of undersigned
counsel only on November 16, 2014;
2. Defendant was served with Summons and copy of
the Complaint on October 28, 2014 and thus has until
November 18, 2014 within which to submit an Answer or
Responsive Pleading;
3. However, due to the pressures of equally pressing
and 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 five (5)
from today
within which to submit Defendant's
Answer.
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 the decision of
this Honorable Court 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 five
(5) days from today within which to submit an Answer or
other Responsive Pleading.
Other relief just and equitable are likewise prayed for.
City of Iloilo, Philippines, November 22, 2014.
PEARSON-SPECTER LAW FIRM
Counsel for the Defendant
Wenceslao de la Paz AV Hall, University of San Agustin
Iloilo City
By:
DONI JUNE V. ALMIO
Roll No. 89765
IBP No, 54321/1-3-2012/Manila
PTR No. 34567/1-3-2012/Manila
Copy furnished:
ATTY. BOLSHEVIK Z. KGAWEGHY
Counsel for the Plaintiff
Unit 12 Times Square Building
General Luna Street, Iloilo City
EXPLANATION
1. That the defendant only hired the services
undersigned counsel on November 16, 2014, two days
before the deadline for the filing of the complaint.
2. Such being said, the counsel does not have enough
time to study the case.
3. That the counsel is not able to interview the
witnesses to the case for reasons of time constraint.
4. That if given the extension, the counsel can fully
assure this Honorable Court that the answer can be filed on
the date for the deadline of the extension.

NOTICE
Copy of the foregoing MOTION was served to
plaintiffs counsel by served in person by a staff of the
undersigned.
DONI JUNE V. ALMIO (SGD)
Counsel for The Defendant