Republic of the Philippines

Department of Trade and Industry

Construction Industry Authority of the Philippines
Construction Industry Arbitration Commission
2/F Executive Building Center
369 Sen. Gil J. Puyat Ave. cor. Makati Ave., Makati City
 
 
 

MOTION FOR POSTPONEMENT WITH

REQUEST FOR EXTENSION OF TIME
TO PRODUCE DOCUMENTS

1. The above-captioned case was previously scheduled for

continuation of preliminary conference on 11 October 2021 at 8:30 a.m.

2. On October 5, 2021, we received from Claimant a

Manifestation and Compliance (Re:

3. The Claimant’s Manifestation and Compliance and its annexes

was sent to Respondents through numerous email tranches. is still
downloading the 163 PDF files attached to 106 emails of Claimant TRDCI.

4. Further, on October 5, 2021 we likewise received from Claimant

TRDCI a Request for Production of Documents, praying for an order
directing Respondent to produce documents listed in pars. 4(a) to 4(e) and
Respondent PGAI to produce the documents listed in pars. 5(a) to 5 (e).

5. Furthermore, on October 7, 2021, we received an Order dated

October 6, 2021 from the Honorable Tribunal directing both Respondents
to comply with the Claimant’s Request for Production within (5) days from
receipt of the Order or until October 12, 2021.

6. In view of the foregoing, Respondent manifest that due to its

limited personnel it will take time for both undersigned counsel and
Enerthrust to go through all the files, to sort and to analyze the voluminous
documents recently sent by Claimant and to comply with the Order of the
Honorable Tribunal to produce documents requested.

7. In line with this, the analysis of all documents provided is

necessary for Respondent to summarize our final statement of claims and
in order to admit fact and issues during the preliminary conference hearing
previously scheduled on October 11, 2021.
 8. Thus, the undersigned most respectfully seek the indulgence of
this Honorable Court for the postponement of the hearing scheduled on 11
October 2021 and its resetting to the end of October or any date convenient
to the calendar of this Honorable Tribunal and to give additional 15 days or
until October 22, 2021 for the production of the documents requested.

5. This motion is not intended to delay the proceedings in the

above-captioned case but is prompted solely by the aforementioned reason.

PRAYER

WHEREFORE, in view of the foregoing, it is respectfully prayed to

this Honorable Court that:

1. The scheduled hearing on 11 October 2021 be cancelled and reset

to the end of October, or on any date convenient to the calendar of
the Honorable Tribunal; and

2. Additional 15 days from receipt of the order to comply with the

request for production of documents.

The Respondent further prays for other just and equitable reliefs.
 
Quezon City for Makati City, 7 October 2021.