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Republic of the Philippines

FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 39, Quezon City

ADRIAN ESCOTO CANLAS,

Plaintiff,

-versus- Civil Case No

For: Damages

Karlo Miranda Yusi,

Defendant,

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MOTION FOR EXTENSION OF TIME

Plaintiff, by counsel, respectfully states that:

1. He has been required to file a Reply to defendant’s Answer by 10 January 2014;

2. The undersigned counsel, however, anticipates his inability to file the Reply on or
before said due because of the tremendous pressure of other equally urgent
professional work requiring the preparation of pleadings and almost daily trial
appearances before the various courts within and outside Metro Manila. For this
reason, the undersigned is constrained to ask for an additional fifteen days (15)
from 10 January 2014 within which to submit the plaintiff’s Reply.
3. This motion is not intended for delay but is motivated only by the foregoing
reason.

WHEREFORE, plaintiff respectfully prays that he be granted additional fifteen

days (15) days from 10 January 2014, within which to submit plaintiff’s Reply.

Quezon City, Philippines, December 27, 2013

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Atty. Edward Sanchez

Commission Serial No. 14786
Until December 31, 2013
Roll of Attorney 78956
IBP No. 547698/January 1, 2005/ Manila
P.T.R No. 546468/ January 1, 2013
Roll No. 2256
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NOTICE AND REQUEST

THE CLERK OF COURT

RTC Branch 39, Quezon City

Atty. Ronelle F. Galang

GALANG LAW OFFICE

Quezon City, Philippines

Greetings!

Please note that on 3 January 2014, at 8:30 o’ clock in the morning or as soon as
the undersigned counsel may be heard, he will submit the foregoing motion for the
consideration and approval of the Honorable Court.

Atty. Edward Sanchez

Copy Furnished:

Atty. Ronelle F. Galang

GALANG LAW OFFICE
Quezon City, Philippines