REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

1st JUDICIAL REGION
BRANCH 416B
BAGUIO CITY

PROF E. SSOR, Civil Case No. _____

Plaintiff, For: Collection of Sum of
Money with Prayer of writ
-versus- for the issuance of
Preliminary Attachment
DO C. TOR,
Defendant.

x---------------------------------------------x

MOTION FOR EXTENSION OF TIME TO

FILE AN ANSWER

Defendant to the Honorable Court most respectfully state:

1. That he was given by the Honorable Court to submit his Answer in

the above-titled case fifteen (15) days from service of the summons or until
September 6, 2019;

2. As he is still in the process of gathering evidence including

documents and testimonies of witnesses to be incorporated to his Answer.
They request that they be given additional fifteen days or until September 21,
2019 to submit the Answer

PRAYER

WHEREFORE, defendant most respectfully pray that the Honorable

Court GRANTS this Motion and give the defendant additional fifteen days or
until September 21, 2019 to submit his Answer and supporting documents, if
any.
 Other reliefs which are just and equitable in the premises are also prayed
for.

Baguio City, Philippines. August 22, 2019.

DEFEND AND ASSOCIATES

Counsel for the Defendant
#02 Upper Session Rd., Baguio City
Tel. No. 420-0000 | e-mail: defendandassociates@gmail.com

ATTY. DEFEND D. POOR

#2 Upper Session Rd., Baguio City
Roll No. 111111
IBP No. 01111111/June 13, 2018
Baguio-Benguet Chapter
PTR No. 1111111/June 06, 2019
MCLE Certificate of Compliance No. 2222222
 NOTICE OF HEARING

THE BRANCH CLERK OF COURT

RTC - Branch 416B
Baguio City

Greetings!

Kindly submit the foregoing motion for consideration and approval of

this Honorable Court immediately upon receipt hereof.

ATTY. DEFEND D. POOR

#2 Upper Session Rd., Baguio City
Roll No. 111111
IBP No. 01111111/June 13, 2018
Baguio-Benguet Chapter
PTR No. 1111111/June 06, 2019
MCLE Certificate of Compliance No. 2222222

Copy furnished:

HON. JUDGE GLENDA SORIANO

Presiding Judge
Regional Trial Court
Branch 416B, Baguio City

ATTY. KING ANTHONY M. MONTEREAL

Counsel for the Petitioner
DMO Law Office
#1 Upper Session Rd., Baguio City

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

ATTY. DEFEND D. POOR

#2 Upper Session Rd., Baguio City
Roll No. 111111
IBP No. 01111111/June 13, 2018
Baguio-Benguet Chapter
PTR No. 1111111/June 06, 2019
MCLE Certificate of Compliance No. 2222222
 EXPLANATION
(Pursuant to Section 5, 7, & 11 Rule 13, 1997 Rules of Civil Procedure)

The foregoing Motion For Extension of Time is served by registered mail

as personal service is not practical because of time, distance and manpower
constraints.

ATTY. DEFEND D. POOR

#2 Upper Session Rd., Baguio City
Roll No. 111111
IBP No. 01111111/June 13, 2018
Baguio-Benguet Chapter
PTR No. 1111111/June 06, 2019
MCLE Certificate of Compliance No. 2222222