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Republic of the Philippines

FIRST JUDICIAL REGION


REGIONAL TRIAL COURT
Branch 39, Manila City

ABC CORP. Philippines, Inc.


Plaintiff,
Civil Case No.: 920813
-versus-
For: Specific Performance
XYZ Philippines, et al.
Defendant.
x---------------------------------x

MOTION FOR EXTENSION OF TIME TO FILE ANSWER

PLAINTIFF, by counsel, respectfully states that:


(1) We have been required to file a Complaint by 23 March 2019;
(2) We, however, have been heavily burdened with Midterms (in Agency under
Professor Ryan Oliva and Administrative Law under Professor Michael Tiu)
for the past days and have been unable to thoroughly study the Fact Sheets
and Contracts in order to prepare an adequate draft for our Complaint. For
this reason, the undersigned is constrained to ask for an additional three (3)
days from 23 March 2019 within which to submit the Complaint;
(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


three (3) days from 23 March 2019, or until 26 March 2019, within which to
submit plaintiff’s Answer.

Manila City, Philippines; 22 March 2019.


ATTY. Patricio Espinosa
Counsel for the Plaintiff
Palace Building, 36 9th Ave, Bonifacio Global City, Taguig City, Metro Manila,
PTR No. 888801; 01/04/2012; Quezon City
IBP OR No: 8938291; 01/04/2012; Quezon City
Roll No.: 33091; 04/08/2005
Quezon City, Philippines
TIN No. 321-897-332-145
NOTICE AND REQUEST

THE CLERK OF COURT


RTC Branch 39, Quezon City

ATTY. RAYMONELLE R. REYES


REYES & RODOLFO LAW OFFICE
Quezon City, Philippines

Greetings!

Please note that on 26 March 2019, at nine 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. Patricio Espinosa

Copy Furnished:

ATTY. BALINDONG
ROMAN, PARULAN, BALINDONG and JACINTO LAW OFFICE
Quezon City, Philippines

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