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Republic of the Philippines

REGIONAL TRIAL COURT


Second Judicial Regional
Branch 03
Hall of Justice
Carig, Tuguegarao City

JOSEPH D. TALAY,
Plaintiff,

-versus- CIVIL CASE NO. 8833


For: “REVIVAL OF JUDGMENT”
CHRISTOPHER A. FLORES,
Defendant.
x--------------------------------------------------x

ENTRY OF APPEARANCE
WITH MOTION FOR EXTENSION OF TIME TO FILE ANSWER

Respondent, CHRISTOPHER A. FLORES, through the undersigned


counsel, respectfully states:

The undersigned law firm enters its appearance as counsel or any


of its counsels for the defendant. Henceforth, it is most respectfully
prayed that all pleadings, notices, orders, resolutions and other
processes of the Honorable Court in connection with the above-
captioned case be directed to the following address:

CUMIGAD LAW OFFICES


2D Arellano Street, Ugac Sur
Tuguegarao City

Conforme:

CHRISTOPHER A. FLORES

On the Motion for Extension of Time to File Answer:

1. Respondent, Christopher A. Flores, received a copy of the


Order to submit his Answer together with the copy of the Complaint on
25 January 2019.

2. Respondent was ordered to submit his Answer within


fifteen (15) days from his receipt of the Order.
3. It is most respectfully manifested that herein defendant only
secured the services of the undersigned law office on 29 January 2019.

4. It is most respectfully prayed that the undersigned be given


an extension of fifteen (15) days from 29 January 2019 or until 13
February 2019 within which to file his Answer.

5. This motion is not intended to delay the proceedings but is


prompted solely by the above-stated reason.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed


that respondent be given an extension of fifteen (15) days or until 13
February 2019 within which to file his Answer.

Such other reliefs deemed just and equitable under the premises
are likewise prayed for.

Respectfully submitted.

05 February 2019.

Tuguegarao City.

CUMIGAD LAW OFFICES


2D Arellano Street, Ugac Sur
Tuguegarao City

By:
ROTCIV R. REYES
Roll No. 68067
IBP ____/01-07-2019
PTR No. 25099378/02-04-2019/Tuguegarao City
MCLE Exempt

EXPLANATION

Due to the distance between the office of the undersigned


counsel and the counsels for the other parties and the dearth of a
messenger, personal service of this Entry of Appearance with Motion for
Extension of Time to File Answer is impracticable, hence, service is made
through registered mail.
MARY GRACE V. PULIDO SADIAN

Copy furnished:

BONIFACIO ALBINO B. PATTAGUAN, JR.


Counsel for Plaintiff
2nd Floor, Cabling Merhandising,
CaggayHighway, Tuguegarao City, Cagayan