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.
Indian Bank v. Maharashtra State Coop. Marketing Federation, AIR 1998 SC 1952 Trikamda Jethabhai v. Jivraj Kalianji AIR 1942 Bombay, 314 Code of Civil Procedure, 1908 S 10