Republic of the Philippines

REGIONAL TRIAL COURT

11th Judicial Region
JUSTICE ON WHEELS
Glan, Sarangani Province
-oOo-

HEIRS OF SUMPAO ONDONG CIVIL CASE NO. 0016-17

AND LAMBA ONDONG namely
JAHILA ONDONG, GUIMBO -for-
ONDONG, EMBUAN ONDONG,
CALUDIN OMBONG, MAHIDDIN Judicial Partition/Settlement
of
ONDONG, BOLAN ONDONG Estate, Reconveyance and/or
AND LEYA ONDONG represented Recovery of Possession,
TOTING M. KAY as Attorney-in- Accounting Damages and
Fact, Attorney’s Fees with Prayer
for a Writ of
Preliminary
Plaintiffs. Mandatory and/or
Prohibitory
Injunction and Temporary
-versus- Restraining Order

ESMAEL HADJI USOP,

MONGERIN ONDONG, TAHIR
PALA USOP, FATIMA PALA
AND OTHER PERSONS
CLAIMING RIGHTS UNDER
THEM,
Defendants.
x--------------------------------------x

MOTION FOR EXTENSION TO FILE ANSWER

Defendants through counsel from the Public Attorney’s

Office, unto this Honorable Court, most respectfully states, THAT;

1. Defendant engaged the services of undersigned counsel

only on January 16, 2018;

Page 1 of 4 Pages

2. Defendant was served with Summons and copy of the

Complaint on January 10, 2018 and thus has until January
25, 2018 within which to submit an Answer;
 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 15 days from today within which to
submit Defendants’ Answer. 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, Defendants most respectfully pray on this

Honorable Court that they be given an additional period of 15
days from today or on February 06, 2018 within which to submit
an Answer.

January 22, 2018. Alabel, Sarangani Province.

Respectfully submitted:

PUBLIC ATTORNEY'S OFFICE

Department of Justice
Sarangani District Office
Alabel, Sarangani Province
By:

BAI ALEFHA HANNAH M. MUSA-

ABUBACAR
Public Attorney I
Noted by:

SALVADOR G. TALAMAYAN
OIC- District Public Attorney

Page 2 of 4 Pages

NOTICE OF HEARING

The Clerk of Court

Branch 35, RTC
11th Judicial Region

G r e e t i n g s:
 Please take notice that the foregoing MOTION will be
submitted for the resolution of the Honorable Court.

BAI ALEFHA HANNAH M. MUSA-

ABUBACAR

Atty. ROSALIO C. CARIŇO

Counsel for Pllaiintiffs
Ground Floor, Arenas Bldg.
Pioneers Avenue, Dadiangas West
General Santos City

Atty. ARTURO C. CLOMA

Co-Counsel for the Plaintiff
Mezzanine Floor, Arenas Bldg.
Pioneers Avenue, Dadiangas West
General Santos City

G r e e t i n g s:

Please be informed that the undersigned will submit the

foregoing motion for Extension of time to file answer and approval
of the Honorable Court on 23 January 2018 at 9:00 o’clock in the
morning.

BAI ALEFHA HANNAH M. MUSA-

ABUBACAR

Page 3 of 4 Pages

EXPLANATION

Service of the foregoing pleading to the counsel for the plaintiffs

was made thru registered mail due to distance, manpower and
time constraint.

BAI ALEFHA HANNAH M. MUSA-

ABUBACAR
Registry Receipt No.________
Date ___________

Page 4 of 4 Pages
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