Motion For Extension Of Time 421b61

Republic of the Philippines FIRST JUDICIAL REGION REGIONAL TRIAL COURT Branch 39, Quezon City FERNANDO A. SAN AGUSTIN, Plaintiff, Civil Case No.: 920813 -versusFor: DAMAGES MANNY L. OTTO, Defendant. x---------------------------------x

MOTION FOR EXTENSION OF TIME PLAINTIFF, by counsel, respectfully states that: (1) He has been required to file a Reply to defendant’s Answer by 10 January 2013; (2) The undersigned counsel, however, anticipates his inability to file the Reply on or before said due date because of the tremendous pressure of other equally urgent professional work requiring the preparation of pleadings and almost daily trial appearances before the various courts within and outside Metro Manila. For this reason, the undersigned is constrained to ask for an additional fifteen (15) days from 10 May 2013 within which to submit the plaintiff’s Reply; (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 fifteen (15) days from 10 January 2013, or until 25 Jnauary 2013, within which to submit plaintiff’s Reply. Quezon City, Philippines; 27 December 2012.

ATTY. GELIE ERIKA P. ESTEBAN Counsel for the Plaintiff 3F La Azotea Bldg., Session Road, Baguio City

PTR No. 99909; 01/04/2012; Baguio City IBP OR No: 6928764; 01/04/2012; Baguio City Roll No.: 81319; 04/08/2005 Baguio City, Philippines TIN No. 143-444-434-000

NOTICE AND REQUEST THE CLERK OF COURT RTC Branch 39, Quezon City ATTY. REY M. ABANADOR ABANADOR-LIM LAW OFFFICE Qeuzon City, Philippines

Greetings! Please note that on 3 January 2013, at 8:30 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. GELIE ERIKA P. ESTEBAN

Copy Furnished: ATTY. REY M. ABANADOR ABANADOR-LIM LAW OFFFICE Qeuzon City, Philippines Pg136