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Motion For Extension of Time To File Answer Ad Cautelam: Penshone Inc.

The document is a motion filed by Stephanie Villarico Abangan, counsel for the respondents (Yungchow Corporation, Choi Soo Hwang, and Yoon Seri), requesting a 10-day extension to file an answer in the civil case of Penshone Inc. vs. Yungchow Corporation et al. for specific performance and damages. The motion states that counsel was only engaged on March 27th and needs additional time to interview witnesses and further study the case due to equally urgent work and prior commitments. The motion is not intended for delay but to address the stated reasons, and prays that the court grant the 10-day extension.

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361 views4 pages

Motion For Extension of Time To File Answer Ad Cautelam: Penshone Inc.

The document is a motion filed by Stephanie Villarico Abangan, counsel for the respondents (Yungchow Corporation, Choi Soo Hwang, and Yoon Seri), requesting a 10-day extension to file an answer in the civil case of Penshone Inc. vs. Yungchow Corporation et al. for specific performance and damages. The motion states that counsel was only engaged on March 27th and needs additional time to interview witnesses and further study the case due to equally urgent work and prior commitments. The motion is not intended for delay but to address the stated reasons, and prays that the court grant the 10-day extension.

Uploaded by

Steph Rent
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd
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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


Cebu City
Branch 24

PENSHONE INC.,
Plaintiff,
CIVIL CASE No. 1234
-versus- FOR: Specific Performance
With Damages
YUNGCHOW CORPORATION,
Choi Soo Hwang, and Yoon Seri,
Respondent.
x----------------------------------------------------x

MOTION FOR EXTENSION OF TIME


TO FILE ANSWER AD CAUTELAM

THE BRANCH CLERK OF COURT


Regional Trial Court
Cebu City – Branch 24

RESPONDENT, by counsel, respectfully alleges that:

1. Respondents engaged the services of undersigned counsel only

on March 27, 2020;

2. Respondents was served with Summons and copy of the


Plaintiff’s Complaint on March 19, 2020 and thus has until April

3, 2020 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;

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

additional period of ten (10) days from today


within which to submit Respondent'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, Respondents most respectfully prays of this Honorable


Court that he be given an additional period of ten (10) from today

within which to submit an Answer or other Responsive Pleading.

Other relief just and equitable are likewise prayed for.

Cebu City, Philippines, 31st of March 2020.

STEPHANIE VILLARICO ABANGAN


COUNSEL FOR THE RESPONDENT
Roll No. 970624
IBP Lifetime No. 2013006371/1-3-19/Cebu
PTR No. 041370/12-30-19/Cebu
With conformity:

YUNGCHOW CORPORATION
By:

CHOI SOO HWANG

Copy furnished:

ABBOT NESTLE
Counsel for the Plaintiff
Unit 624 Nestle Building
Cebu City

NOTICE OF HEARING

THE BRANCH CLERK OF COURT


RTC - Branch 24
Cebu City

Greetings!

Kindly submit the foregoing motion for consideration and


approval of this Honorable Court immediately upon receipt hereof.

STEPHANIE V. ABANGAN
Counsel for the Respondent
Copy furnished by registered mail:

ATTY. ABBOT NESTLE


Counsel for the Plaintiff
Cebu City

Please take notice that counsel has requested for the


approval of this motion immediately upon receipt.

STEPHANIE V. ABANGAN
Counsel for the Respondent

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