REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

SECOND JUDICIAL REGION
BRANCH 35
SANTIAGO CITY

GLOBE TELECOM, INC.,

Plaintiff,

-versus - CIVIL CASE NO. 35-3661

THE CITY GOVERNMENT OF

SANTIAGO CITY, REPRESENTED
BY ITS HONORABLE MAYOR
AMELITA SISON-NAVARRO,
Defendant.
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MOTION FOR EXTENSION OF TIME TO FILE

COMMENT

Defendant City Government of Santiago City, through the

Office of the Solicitor General (OSG) respectfully states:

1. On 4 April 2011, the OSG was served a copy of the Order

dated 21 March 2011 ordering the OSG to file its Comment or

Opposition to the Complaint within five (5) days from notice. Thus,

it has until 9 April 2011 within which to file the required pleading.

2. However, due to pressure of work from other cases of

Motion for Extension..... 2
Globe Telecom vs. City Gov't of Santiago City
Civil Case No. 35-3661
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equal importance, additional time is needed to prepare the required

pleading.

3. Thus, undersigned counsel respectfully requests for an

additional period of thirty (30) days from 9 April 2011 or until 9

May 2011 within which to prepare and file the required Comment.

PRAYER

WHEREFORE, it is respectfully prayed that undersigned

counsel be given an additional period of thirty (30) days from 9 April

2011 or until 9 May 2011 within which to file its Comment.

Respectfully submitted.

Makati City for Santiago City, 5 April 2011.

JOSE ANSELMO I. CADIZ

Solicitor General
IBP Lifetime No. 02819
Roll No. 35072
MCLE Compliance No. III-000920

DEREK R. PUERTOLLANO
Motion for Extension..... 3
Globe Telecom vs. City Gov't of Santiago City
Civil Case No. 35-3661
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Assistant Solicitor General

Roll No. 36444
IBP Lifetime No. 01927
MCLE Compliance No. III-0003826

JOHN ANDREW R. SALAZAR

State Solicitor II
Roll No. 47170
IBP No. 789321
MCLE Compliance No. III-0003838
OFFICE OF THE SOLICITOR
GENERAL
134 Amorsolo St., Legaspi Village,
Makati City
Email Address: jarsalazar@osg.gov.ph
Telephone No.: 8127980

Copy Furnished:

Salalima Castelo & Ungos

Counsel for the Plaintiff
5/F Globe Telecom Plaza
Pioneer cor. Madison Sts.
1552 Mandaluyong City

EXPLANATION
(Pursuant to Rule 13, Section 11 of the 1997 Rules of Civil Procedure)

The foregoing Motion for Extension is being filed and served by registered
mail, personal filing and service being impracticable due to distance and lack of
personnel.

JOHN ANDREW R. SALAZAR

State Solicitor II

DRP/JARS/mtl: globe vs. city gov't of santiago4.5.11/10-070529

Motion for Extension..... 4
Globe Telecom vs. City Gov't of Santiago City
Civil Case No. 35-3661
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