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REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION


REGIONAL TRIAL COURT
BRANCH 6, MANILA

BPI FAMILY SAVINGS BANK, INC.,


Plaintiff,

- Versus - Civil Case No. 17-


138111
For: Replevin and
Damages

JEROME E. ANDICOY, JOANNE E.


ANDICOY AND JOHN DOE

FORMAL ENTRY OF APPEARANCE


AND
MOTION FOR EXTENSION TO FILE
COMMENT

Defendant, by the undersigned counsel, and unto this


Honorable Office of the Regional Trial Court, most
respectfully states that:

1. The undersigned formally enters its appearance as


counsel for complainant in this case. Please have all
notices and orders of this Honorable Court in this case
be addressed to the undersigned and sent to:
Valera Burns Montero Tria and Partners Law
Office
Unit 4 & 6 2/F Corinthian Plaza Bldg. 121 Paseo
de Roxas St. cor. Legaspi St. Legaspi Village,
Makati City, Philippines

2. The Order of this Honorable Court dated 4 May 2017


directs the Defendant to submit a comment to the
Plaintiff’s Motion for Execution within fifteen (15) days or
until 4 August 2017;

3. However, the undersigned counsel foresees the inability


to file the required Answer within the period given
therefor on account of the fact that the legal services of
the undersigned Law Firm has been engaged by the
Defendants only recently and considering the volume of
other equally important professional work, including, but
not limited to, attendance in court hearings, drafting of
pleadings, and meetings and conferences with clients,
which the undersigned is concurrently attending to.
Likewise, the numerous allegations of facts stated in the
Complaint require extensive verification of records and
information material and relevant thereto in order to
fully address the said Complaint;

4. As such, undersigned counsel is respectfully requesting


the indulgence and understanding of this Honorable
Court, for reasons of fair play and equity, that the
undersigned be given an extension of fifteen (15) days
from today to submit its comment to the said Motion for
Execution;

5. This Motion is not intended for delay but solely


due to the foregoing reasons.
6. WHEREFORE, based on the premise presented, it is
most respectfully prayed that the hearing of the instant
case be set after fifteen (15) days, subject to the
Honorable Court’s calendar.

This is hereby submitted today, 4 August 2017, City of


Makati for City of Manila.

FELICIANO L. MACARAEG III


Counsel for the Defendant
Roll No. 69670
IBP No. 003397/5-12-17/Manila
PTR No. 4774580/6/14/2017
MCLE Compliance No. N/A (admitted to the bar
3 June 2017)

NOTICE:

BRANCH CLERK OF COURT


REGIONAL TRIAL COURT
Branch 6, City of Manila

Atty. Cesar Bernard R. Coloma


BPI LEGAL AFFAIRS AND DISPUTE RESOLUTION
DIVISION
Counsel for Plaintiff 14th Floor, BPI Bldg., Ayala Ave. corner
Paseo De Roxas, Makati City
Greetings!

Please submit the foregoing Motion for the consideration


and approval of the Court immediately upon receipt hereof.

Thank you.

FELICIANO L. MACARAEG III

COPY FURNISHED:

Atty. Cesar Bernard R. Coloma


BPI LEGAL AFFAIRS & DISPUTE
RESOLUTION DIVISION
Counsel for Plaintiff 14/F
BPI Bldg., Ayala Ave. cor.
Paseo De Roxas, Makati City

EXPLANATION

The foregoing Motion has been sent through a registered


mail due to lack of personnel to provide for personal delivery.

FELICIANO L. MACARAEG III