REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

ANGELES CITY
PROVINCE OF PAMPANGA
BRANCH 57

F.F. MAISON CORPORATION

Plaintiff,

-versus- Civil Case No. XJV-18M-113-2

For: Rescission of Deed of
Absolute Sale with Damages

FTL & SONS CORPORATION

Defendant.

x-----------------------------------------------------x

MOTION FOR EXTENSION OF TIME

PLAINTIFF, by counsel, respectfully states that:

1) On February 13, 2020, the plaintiff received a copy of the Defendant’s

Motion to Dismiss dated February 10, 2020. Hence, pursuant to the
order of the Honorable Court, the plaintiff has three (3) days or until
February 16, 2020 within which to file its Comment to the same;

2) However, due to volume and pressure of work, coupled with other

equally important and urgent professional commitments, the
undersigned counsel cannot complete the said Comment/ Opposition
to Motion to Dismiss within the period required and will need an
additional three (3) days from February 16, 2020 or until February 19,
2020 within which to do so.

3) This motion is being filed due to the reason above-stated and not for
the purpose of delaying the instant case.

PRAYER

WHEREFORE, plaintiff prays that it will be granted an additional three

(3) days from February 16, 2020 or until February 19, 2020 within which to
submit a Comment to the Motion to Dismiss.

Manila City for Angeles City, Pampanga, February 13, 2020.

Manila City for Angeles City, Pampanga, January 30, 2020.

By:

ATTY. JUAN CARLOS LIBRE

Roll No. 2313999
IBP No. : 11223344, June 20, 2013, Bulacan
PTR No.: 0998, September 2, 2016, Manila City
MCLE Compliance No.: VI-02311, April 27, 2019, Manila City
3rd Flr. España Tower, P. Campa St., Sampaloc, Manila
jc.libre@gmail.com
 REQUEST/ NOTICE
(and copy furnish)

BRANCH CLERK OF COURT

Regional Trial Court
Branch 57
Angeles City, Pampanga

ATTY. CHRISTINA A. VILLEGAS

Counsel for the Defendant
Grande Building, Dos Castillas Street, Quezon City

G r e e t i n g s:

Please be notified that the Plaintiff will submit the foregoing Motion
for Extension to file Opposition to Motion to Dismiss for consideration and
and resolution of the Honorable Court
Manila City forimmediately
Angeles City,upon receiptJanuary
Pampanga, hereof,30, 2020.
without need of further appearances and oral arguments from the parties.

By:

ATTY. JUAN CARLOS LIBRE

Roll No. 2313999
EXPLANATION IBP No. : 11223344, June 20, 2013, Bulacan
PTR No.: 0998, September 2, 2016, Manila City
Please be informed thatMCLE
the undersigned
Compliancecounsel causedApril
No.: VI-02311, the 27,
filing of Manila City
2019,
rd
this pleading with the Honorable3Court and theTower,
Flr. España serviceP. ofCampa
a copy on
St.,the other Manila
Sampaloc,
parties in this case by registered mail. The undersigned counsel was unable
jc.libre@gmail.com
to cause the personal filing and service due to the shortage of available
manpower and the distance Manilaof City
the for
office of the
Angeles undersigned
City, Pampanga, with
Januarythe30, 2020.
Honorable Court and the other parties.

By:

ATTY. JUAN CARLOS LIBRE

Roll No. 2313999
IBP No. : 11223344, June 20, 2013, Bulacan
PTR No.: 0998, September 2, 2016, Manila City
MCLE Compliance No.: VI-02311, April 27, 2019, Manila City
3rd Flr. España Tower, P. Campa St., Sampaloc, Manila
jc.libre@gmail.com