Republic of the Philippines

REGIONAL TRIAL COURT

11th JUDICIAL REGION
Branch 55
Davao City

JOSELITO CALEM MANOLOTO Civil Case No. 25653-098

Plaintiff FOR: Recovery of Possession
With Damages
-vs-

ROSA ROSAS,
Defendant.

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

MOTION FOR EXTENSION OF TIME

DEFENDANT, by the undersigned counsel, and unto this Honorable

Court, most respectfully states that:

1. Defendant was served with Summons and copy of the Complaint on

05 November 2020 and thus has until 20 November 2020 within
which to submit an Answer or Responsive Pleading;

2. 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;

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

additional period of five (5) 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;

4. 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 five (5) days from today
within which to submit an Answer or other Responsive Pleading.
Other relief just and equitable are likewise prayed for.

Davao City, Philippines, 28th of February 2020.

NENARIA LAW FIRM

8th floor, ABC Bldg., Ecoland, Davao City
Tel Nos. [082] 555-8888;
E-mail address: janinenenaria31@gmail.com

By:

ATTY. JANINE LOUISE MAE E. NENARIA

Counsel for Defendant
Notary Public for Davao
Notarial Commission No. 2019-09
Until December 31, 2019
Rm. 597 ABC Building, Davao City
Roll No. 7987
PTR No. 59781198/ 2-14-23
IBP Lifetime Member 1993
MCLE No. 0091812-08-09-93
 NOTICE OF HEARING

The Branch Clerk of Court

Regional Trial Court
Branch 55, Davao City

Greetings!

Please submit the foregoing motion to the Court for its consideration
and approval immediately upon receipt hereof and kindly include the same
in the court’s calendar for hearing on April 12, 2020 at 8:30 in the morning.

(SGD) ATTY. JANINE LOUISE MAE E. NENARIA

COUNSEL FOR THE DEFENDANT

Atty. Queenie Reyes

Counsel for the Plaintiff
No. 88 Lemon Town, Davao City

Please take notice that counsel has requested to be heard on April 12,
2020 at 8:30in the morning.

(SGD) ATTY. JANINE LOUISE MAE E. NENARIA

COUNSEL FOR THE DEFENDANT

EXPLANATION AS TO SERVICE

Copy of this Motion to Dismiss was served the counsel for plaintiff
thru registered mail. Personal service cannot be effected due to lack of
manpower, as well as distance and time constraints

ATTY. JANINE LOUISE MAE E. NENARIA

Copy Furnished:
Atty. Queenie Reyes
Counsel for the Plaintiff
QR LAW OFFICES
Room 5 ABC Building, Ecoland, Davao City