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Form No. 1--Motion for Extension of Time to File Answer Responsive Pleading

(Motion for Extension of Time to File Answer Responsive Pleading)

(CAPTION)

MOTION FOR EXTENSION OF TIME

DEFENDANT, by the undersigned counsel, and unto this Honorable Court, most respectfully states that:

1. Defendant engaged the services of undersigned counsel only on _____________;

2. Defendant was served with Summons and copy of the Complaint on _____________ and thus has until _____________ 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 _____________ from today within which to submit Defendant'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.

P R A Y E R

WHEREFORE, Defendant most respectfully prays of this Honorable Court that he be given an additional period of _____________ from today within which to submit an Answer or other Responsive Pleading.

Other relief just and equitable are likewise prayed for.

_____________, Philippines, __Date__.

(COUNSEL)

(NOTICE OF HEARING)

(EXPLANATION)

COPY FURNISHED:

OPPOSING COUNSEL

 

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