REPUBLIC OF THE PHILIPPINES

FOURTH JUDICIAL REGION

METROPOLITAN TRIAL COURT
Bacoor City, Cavite
Branch 7

JACKIE CHAN DELA CRUZ

Plaintiff,
Civil Case No: 100121
For Sum of Money
-versus-

ALBERTO ISAAC TOLENTINO,

Defendant.

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MOTION FOR EXTENSION OF TIME

TO FILE COMMENT TO OFFER OF EVIDENCE

Defendant, by counsel, respectfully alleges that:

1. On May 15, 2023, he received a copy of the plaintiff's Offer of Evidence dated
April 25, 2023. Hence, pursuant to the order of the Honorable Court in open
court during the May 7, 2023 hearing, defendant has five (5) days or until May
12, 2023 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 to the Offer of Evidence within the period
 required and will need an additional ten (10) days from May 12, 2023 or until
May 22, 2023 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.

WHEREFORE, defendant prays that he be granted an additional ten (10) days from
May 12, 2023, or until May 22, 2023 within which to submit a Comment to the Offer
of Evidence.

Quezon City, Philippines. May 18, 2023.

ATTY. KEVIN K. ANTONIO

Counsel for the Defendant
Upper Ground Floor, Emerald Blg. Makati City, Philippines
Lifetime IBP No. 2352/ 04 Jan. 2023 / Manila City
PTR: 2424 / 04 Jan 2021 / Manila City
Roll No. 32424
MCLE Compliance No. V – 0019608, Issued dated 21 April 2023
 NOTICE OF HEARING

THE BRANCH CLERK OF COURT

RTC - Branch 7
Bacoor City

Greetings!
Kindly submit the foregoing motion for consideration and approval of this Honorable
Court immediately upon receipt hereof.

Copy furnished by registered mail:

ATTY. TESSA E. DIMAGIBA
Counsel for the Plaintiff
Lifetime IBP No. 212112/ 04 Jan. 2019 /Manila City
PTR: 323243 / 04 Jan 2021 / Manila City
Roll No. 12124242
MCLE Compliance No. V – 0019608, Issued dated 21 April 2022

Please take notice that counsel has requested for the approval of this motion
immediately upon receipt.