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Republic of the Philippines

DEPARTMENT OF AGRARIAN REFORM


DAR NUEVA ECIJA PROVINCIAL OFFICE
Mabini Estension, Cabanatuan City
Nueva Ecija

BUREAU OF AGRARIAN LEGAL ASSISTANCE

HEIRS OF FEDERICO
MENDOZA, rep. by
ERLINDA M. SAYSON,
Petitioner,

-versus-
ALI CASE NO. ______________
FOR: Identification and
TERESITA C. BUNAG rep. Declaration as Farmer-
by IRYN P. ESGUERRA, Beneficiary
PERFECTO SORIANO,
SUSANA SORIANO and
RENATO DELA CRUZ,
Private Respondent/s.

MARO OF LUPAO, N.E.,


PARO-NUEVA ECIJA, and
REGISTER OF DEEDS of
NUEVA ECIJA,
Nominal Party Respondents.
x- - - - - - - - - - - - - - - - - - - - - - - x

MOTION FOR EXTENSION OF TIME


TO FILE OPPOSITION/ANSWER WITH
ENTRY OF APPEARANCE

The undersigned is respectfully entering his appearance as


counsel for respondents, Teresita C. Bunag represented by Iryn P.
Esguerra, Spouses Perfecto Soriano and Susana Soriano and Renato
dela Cruz in the above-entitled case. Henceforth, all processes,
pleadings and papers is/are requested to be duly furnished to the
undersigned at his Law Office address as shown herein-below;

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On 23 November 2017, the respondents received a letter from
this Honorable Office requiring them to answer the petition within
ten (10) days from receipt or until 3 December 2017. Since the legal
services of the undersigned counsel has just been retained today
coupled with his daily court appearances and submission of
pleadings on other equally important cases, an extension of ten (10)
days from 3 December 2017 or until 13 December 2017 is being
prayed for them to submit their Opposition/Answer in this instant
case;

WHEREFORE, it is most fervently prayed of this Honorable


Office to take notice of this Entry of Appearance and grant the
undersigned counsel another ten (10) days from 3 December 2017 or
until 13 December 2017 to submit respondents Opposition/Answer
in the interest of due process and substantial justice;

Such other relief and remedy that is deemed just and equitable
under the circumstances is being prayed for.

Santiago City for Cabanatuan City, Nueva Ecija, 3 December


2017.

THE LAW OFFICES OF DAMASEN & SUBIA


Unit 5, Mango Suites, Calao East, Santiago City
E-mail: lmdlawoffice@gmail.com
Mobile No.: 09178730405
Tel. No.: (078) 305-2392

By:

ATTY. LUCKY M. DAMASEN


Counsel for the Defendants
MCLE Compliance No. V-008089/06-04-15
PTR No.2050681/Santiago City/01-03-2017
IBP No. 1049534/Ilagan City, Isabela/01-03-2017
Roll No.37959/07-24-92

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WITH OUR CONFORMITY:

IRYN P. ESGUERRA PERFECTO R. SORIANO


Respondent Respondent

SUSANA SORIANO
Respondent

Copy furnished:

Atty. Thristan B. Escudero


Counsel for the Petitioner
2nd Floor Wisco Building,
T. Delos Santos St. Science City
of Muoz, Nueva Ecija
/by reg. mail w/ ret. card

Explanation pursuant to Section 11, Rule 13 of the


1997 Rules of Civil Procedure

Copy of this Motion for Extension of Time with Entry of


Appearance was duly served to Atty. Thristan B. Escudero via
registered mail with return card instead of personal service due to
time constraints and lack of personnel to effect personal service.

RYAN JAY P. BAEZ