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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


7th Judicial Region
Branch 50
Cebu City

PSBANK,
Plaintiff,

-versus- Civil Case No. CEB 1234


For: Replevin/ Recovery
of Personal Property
JUAN VILLORDON
Defendant.
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MOTION FOR EXTENSION OF TIME

DEFENDANT, by the undersigned counsel, and unto


this Honorable Court, most respectfully states that:

1. Defendant engaged the services of undersigned


counsel only on May 4,2018;

2. Defendant was served with Summons and copy of


the Complaint on April 24, 2018 and thus has
until May 9, 2018 within which to submit an
Answer or Responsive Pleading;

3. However, due to the pressures of equally


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)
days from today within which to submit
Defendant's Answer or Responsive Pleading.
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 but
solely due to the foregoing reasons.

P R A Y E R

WHEREFORE, Defendant most respectfully prays of


this Honorable Court that he be given an additional
period of five days from today within which to submit
an Answer or other Responsive Pleading.

Other relief just and equitable are likewise


prayed for.
Cebu City, Philippines, May 8, 2018.

ATTY. SHAMU M. SAYSON


Counsel for the Defendant
Lightsaber St. Banilad, Cebu City
Tel.No. 032-487 6347

NOTICE OF HEARING

Atty. SANDRA JANE N. SOON


Counsel for the Plaintiff
Governor M. Cuenco Ave., Banilad, Cebu City

Greetings: Please take notice that the foregoing


Motion for Extension of Time to File Pleading shall
be submitted for the consideration and approval of
the Honorable Court on Friday, May 11, 2018, at 10:00
AM or as soon as counsel and matter may be heard.

ATTY. SHAMU M. SAYSON


Counsel for the Defendant
Lightsaber St. Banilad, Cebu City
Tel.No. 032-487 6347

Copy Furnished:

Atty. SANDRA JANE N. SOON


Counsel for Plaintiff
M. Gov. Cuenco Ave., Banilad, Cebu City

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