Republic of the Philippines

SUPREME COURT
MUNICIPAL TRIAL COURT IN CITIES
8th Judicial Region
Ormoc City

ROD JUN E. MELENDRES, RAY

VINCENT E. MELENDRES, AND
ROSS KENNETH E. MELENDRES,
represented by ROSALINDA E.
MELENDRES,
Plaintiffs,

-vs-
CIVIL CASE NO. M-ORM-19-00005-CV
For: RECOVERY OF POSSESSION
WITH DAMAGES

SAMUEL W. EAMIGUEL,
Defendant.
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APPEARANCE AS COUNSEL AND

MOTION FOR EXTENSION
OF TIME TO FILE ANSWER
AND/OR ANY APPROPRIATE PLEADING

Comes now Atty. Gilianne Kathryn L. Gantuangco-Cabiling unto this

Honorable Court, most respectfully enters her APPEARANCE as counsel for
the Defendant and thereby requests that any and all Notices, Orders, Decisions,
and other processes that may be issued anent the above-captioned case be sent
to:

GANTUANGCO LAW OFFICE

Corner Aviles and San Pedro Streets,
District XIII, Ormoc City, Leyte

BY WAY OF MOTION:

On June 26, 2019, herein Defendant received a copy of a Summons

dated June 25, 2019, with an attached Complaint and annexes thereto, which
require, conformably with the Rules of Court, the filing of an Answer within
fifteen (15) days from receipt thereof. Thus, Defendant has until July 11, 2019
within which to file the required ANSWER.
 However, owing to the fact that the undersigned counsel has just only
been recently and formally engaged to handle and represent the Defendant, she
would be needing additional time within which to craft an Answer and to
further collate and study the records and other pertinent and material
documents in relation to this case. Thus, Defendants, through undersigned
counsel, most humbly and respectfully move for an additional fifteen (15) days,
to be reckoned from the filing of the foregoing, within which to file and submit
the required ANSWER.

WHEREFORE, it is most respectfully prayed of this Honorable Court

that the notice of appearance of the ATTY. GILIANNE KATHRYN L.
GANTUANGCO-CABILING be duly noted and that the DEFENDANT
SAMUEL W. EAMIGUEL be given an additional period of fifteen (15) days
from July 10, 2019 or until July 25, 2019, within which to submit his answer
and/or any appropriate pleading.

Ormoc City, Philippines. July 10, 2019.

Respectfully submitted:

GILIANNE KATHRYN L. GANTUANGCO-CABILING

Counsel for Defendant
Corner Aviles and San Pedro Streets
District XIII, Ormoc City, Leyte
(053) 561-0125/09060530265
PTR No. 5832192 issued on
January 3, 2019, Ormoc City
IBP Lifetime Member No. 015068
Attorney’s Roll No. 65406
TIN 266-471-604
MCLE Compliance No. VI-0025568
valid until April 14, 2022

Copy furnished:

Atty. Joseph Kirby L. Calipayan

Public Attorney’s Office
Ormoc City District
Hall of Justice, Ormoc City, Leyte

GARCIANA CONSUELO P. MIÑOZA

Clerk of Court IV
Municipal Trial Court in Cities, Ormoc City
 NOTICE OF HEARING

GARCIANA CONSUELO P. MIÑOZA

Clerk of Court IV
Municipal Trial Court in Cities
8th Judicial Region, Ormoc City

Greetings!

Please submit the foregoing Entry of Appearance and Motion For

Extension of Time To File Answer and/or Any Appropriate Pleading unto
the Honorable Court for its kind consideration and approval on July 18, 2019
at 8:30 o’clock in the morning or at the soonest possible time that both matter
and counsel can be heard by the Honorable Court.

Thank you very much.

GILIANNE KATHRYN L. GANTUANGCO-CABILING

PROOF OF SERVICE

I HEREBY CERTIFY that I am the messenger of GANTUANGCO

LAW OFFICE and that on July 10, 2019, a copy of the foregoing pleading was
furnished the plaintiff through its counsel, Atty. Joseph Kirby L. Calipayan at
the Public Attorney’s Office, Hall of Justice, Ormoc City, through personal
service.

ALLYSA DARYL A. ASIS