Republic of the Philippines

SUPREME COURT
Eighth (8th) Judicial Region
Regional Trial Court-Branch 24
Bulwagan ng Katarungan
Maasin City, Southern Leyte

JUANA de la CRUZ, CIVIL CASE No. 128967

Plaintiff, FOR: BREACH OF CONTRACT OF
CARRIAGE (ART. 1733 in relation to
Art 1755, etc., New Civil Code of the
-versus- Philippines) WITH DAMAGES

CRUZ D. JUAN,
Defendants.
x---------------------------------------------x

MOTION FOR EXTENSION OF TIME TO

FILE ANSWER
DEFENDANT, by the undersigned counsel, and unto this
Honorable Court, most respectfully states that:

1. Defendant engaged the services of undersigned counsel only on

March 11, 2019;

2. Defendant was served with Summons and copy of the

Complaint on November 24, 2019 and thus has until December
11, 2019 within which to submit an Answer or Responsive
Pleading;

3. However, due to the pressures of equally urgent professional

work and prior commitments, the undersigned counsel will not
be able to meet the said deadline to file answer;

4. As such, undersigned counsel is constrained to request for an

additional period of 15 days from today
within which to submit Defendant's Answer or Responsive
Pleading. Moreover, this additional time will also allow the
undersigned to interview the available witness and study this
case further;
 5. This Motion is not intended for delay but solely due to the
foregoing reasons.
PRAYER

WHEREFORE, Defendant most respectfully prays of this

Honorable Court that he be given an additional period of 15 days
from today within which to submit an Answer or other Responsive
Pleading.
Other relief just and equitable are likewise prayed for.
Maasin City, Southern Leyte, Philippines, November 24,2019.

ATTY. CLOIE ANNE C. SULLA

Attys. Roll No. 51444/ 5-10-06
PTR No. 9005803/1-4-20 Maasin City
IBP O.R. NO. 0989528/01-04-20, Southern Leyte Chapter
MCLE COMPLIANCE NO.: V-0004454/11-12-2014 valid
until 11-12-2020

NOTICE

Atty. Ace Vincent Gertos

Branch Clerk of Court
&
Atty. Jackielyne C. Gaviola
Counsels for the Plaintiff

Please take notice that this motion will be submitted for the
resolution of the Honorable Presiding Judge immediately upon filing
hereof appearance and oral arguments from parties and counsels.

Atty. CLOIE ANNE C. SULLA

Copy furnished:

ATTY. Jackielyne C. Gaviola

Counsel for the Plaintiff
2233 Brgy. Combado, Maasin City, Southern Leyte

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

Atty. Cloie Anne C. Sulla