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XI MOTIONS
E. EXTENSION OF TIME
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
Form No. 2--Motion
for Extension of Time to Submit Counter Affidavit
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