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Form No. 1--Motion for Intervention

(Motion for Intervention)

(caption)

MOTION FOR INTERVENTION

COMES NOW the Intervenor, by the undersigned counsel, and unto this Honorable Court, most respectfully requests for leave to intervene in the above-captioned case, for the following reasons:

That the Intervenor is a purchaser of some of the subdivided portions of Lot No. _______, the subject matter of the above-captioned case;

Form No. 2--Motion for Extension of Time to Submit Counter Affidavit

(Motion for Extension of Time to Submit Counter Affidavit)

(CAPTION)

MOTION FOR EXTENSION OF TIME

Respondent, by the undersigned counsel, and unto this Honorable Office of the City Prosecutor, most respectfully states that:

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

2. Respondent received the subpoena on _____________ and thus has until _____________ within which to submit his counter-affidavit;

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;

Form No. 1--Motion for Execution of Judgment

(Motion for Execution of Judgment)

(caption)

MOTION for execution

COMES NOW Plaintiff, by counsel and unto this Honorable Court, most respectfully states:

That on _____________, the Honorable Court rendered decision on the above-captioned case, ordering as follows:

(State the Dispositive Portion of the Judgment)

That inquiry into the records of this case with this Honorable Court shows that no appeal has been taken from the said decision after it has been rendered by the Honorable Court;

That the reglementary period for appeal has already expired, and said decision is now final, unappeasable and executory.

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;

Form No. 1--Motion to Dismiss

(Motion to Dismiss)

(CAPTION)

MOTION TO DISMISS

COMES NOW the Respondent, _____________ Inc., through the undersigned counsel, appearing especially and solely for this purpose, and to this Honorable Court, most respectfully moves for the dismissal of the Complaint on the following ground that THE HONORABLE COURT HAS NOT ACQUIRED JURISDICTION OVER THE PERSON OF THE DEFENDING PARTY.

DISCUSSION

A cursory reading of the Summons and Return of Service would readily show that the copies of the Summons dated 08 May 2001 and the Complaint and its corresponding annexes were allegedly delivered and tendered upon the Movant _____________ INC. through a certain Maria Clara alleged to be the authorized personnel of Movant _____________ INC., Bacolod City on 29 August 2001. Copies of the said Summons and Return of Service that form part of the records on the case are hereto pleaded as integral part of this Motion;

 

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