For: Replevin/ Recovery of Personal Property JUAN VILLORDON Defendant. x--------------------/
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