Republic of the Philippines

Tenth Judicial Region

REGIONAL TRIAL COURT
Cagayan De Oro City
Branch 18

JOSE REYES,
Petitioner,
Civil Case No.123456
For: Injunction
- Versus -

JUAN DELA CRUZ, in his

capacity as Regional Director of the
Department of Public Works and
Highways, Region 10

X----------------------------------------X

MOTION FOR EXTENSION OF TIME

Respondent, by counsel, to this Honorable Court, respectfully avers
that:

1. On 24 January 2018, Respondent received summons issued by

this Honorable Court, with attached copy of the Petition for injunction filed
against respondent, directing him to file his answer within 10 days from
receipt thereof on until 3 February 2018.

2. On 25 January 2018, an indorsement letter from DPWH Region

10 attached with a copy of said summons was mailed to the OSG, the former
asking the latter for legal representation in said Injunction case.

3. The same was received by the OSG Docket Management

Service on 6 February 2018 and was assigned to the undersigned the
following day.

4. On the same day this case was assigned to her, the undersigned
counsel was scheduled to attend a conference and site ocular inspection in
Isabela, Basilan and only returned to the office on 12 February 2018.

5. However, due to pressures of equally urgent professional work

and prior commitments, the undersigned inadvertently failed to see the
indorsement letter until it was already 15 February 2018, Thursday, with the
following day declared a national holiday.
 6. As such, the undersigned is constrained to request an additional
period of fifteen (15) days from the date of this motion within which to
submit the defendant’s Answer.

7. Hence, it is with profuse apologies, the undersigned interposes

this motion in good faith and without intention of causing delay.

PRAYER
WHEREFORE, premises considered, it is respectfully prayed that the
attached answer be admitted and considered in the resolution of his case.

Respondent also prays for other reliefs as may be deemed just and
equitable in the premises.

Las Pinas City, 19th February 2018

ATTY. MARJORIE CAMILLE FLORES

State Solicitor/ Counsel for the Defendant
Unit 209 Page 1 Bldg. Las Pinas City
Roll No. 155427
IBP No. 22561
PTR No. 8712560
MCLE Compliance No. 0091269
Tel. Nos. 853-4322; 853-4355
Email: mcaf.24@gmail.com

Copy Furnished:

Atty. Daniel Lakwatsa

Counsel for the Petitioner