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Republic of the Philippines

REGIONAL TRIAL COURT
7TH Judicial Region
Branch 58, Cebu City

CEBU EASY GENERAL SERVICES

Plaintiffs.

-versus- Civil Case No. R-CEb-17-04026-CV

RODEO GRILL BARBECUE &

SIZZLERS FOOD CORPORATION,
JAKE MODAY RICARDO & LYNDON
JOSEPH T. SANCHEZ
Defendants.

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MOTION FOR EXTENSION OF TIME TO EFFECT

SUBSTITUTED SERVICE OF SUMMONS

Plaintiff, by the undersigned counsel, and unto this

Honorable Court, respectfully states:
1. On 29 March 2023, the Plaintiff received the Order of the
Court directing the plaintiff to take appropriate action within
fifteen (15 days) from receipt of the Order with respect to
defendants RODEO GRILL BARBECUE & SIZZLERS FOOD
CORPORATION and LYNDON JOSEPH T. SANCHEZ;
2. That Plaintiff has until 13 April 2023, to take the
appropriate action;
3. However, due to the recent long holidays, and the
undersigned counsel’s engagements and hearings before and
after the holidays, she needs additional time to confer with the
plaintiff, and to identify if there are any new addresses, as well
as the email addresses of the respondents, to which the
summons may be served.
4. As such, the respondents are constrained to request for
an additional period of ten (10) days from 13 April 2023 or until
23 April 2023 within which to take appropriate action with
respect to RODEO GRILL BARBECUE & SIZZLERS FOOD
CORPORATION and LYNDON JOSEPH T. SANCHEZ;
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5. The Plaintiff respectfully asks for the indulgence of the

Court in view of the fact that it had been years since the
Sheriff’s Return of Service of Summons was submitted to the
Court and the Plaintiff need to ascertain for any changes in the
addresses of some of the respondents.
6. This Motion is not intended for delay but solely due to the
foregoing reasons.
PRAYER
WHEREFORE, respondents most respectfully pray of this
Honorable Office that she be given an additional period of ten
days from 13 April 2023 or until 23 April 2023 within which to
appropriate action with respect to RODEO GRILL BARBECUE
& SIZZLERS FOOD CORPORATION and LYNDON JOSEPH T.
SANCHEZ.
13 April 2023. Cebu City.

BADUEL * ESPINA & ASSOCIATES

Suite 307, 3rd Floor GMC Plaza Building
Legaspi Ext., cor. M.J. Cuenco Ave.,
Cebu City
Tel No. (032) 254-4626; 254-8403

By:

CHRISTINA ANGELI C. ESPINA-

ABELLANA
Roll No. 65085
PTR No. 4788755- 01.04.23 Cebu
IBP Lifetime No. 018921-Cebu City
MCLE VII-0003797 07.29.21 valid
until 04.14.25
Contact No. 09177069343
Email: cae.abellana@gmail.com
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NOTICE

The Clerk of Court

Regional Trial Court
Branch 58, Cebu City

This is to respectfully inform you that the undersigned

counsel will submit the foregoing Motion for Extension of Time
to the Honorable Court for its favorable consideration and
resolution.

CA Espina-Abellana

EXPLANATION

This Motion for Extension of Time to Serve Summons is filed

before this Honorable Court through electronic mail due to lack
of staff to effect personal filing as the office’s messenger is out
on other errands.

A hard copy of this Motion will also be filed in Court.

CA Espina-Abellana