Entry Of Appearance.docx

REPUBLIC OF THE PHILIPPINES NATIONAL CAPITAL JUDICAL REGION REGIONAL TRIAL COURT xxx

xxx Plaintiff, xxx -versusxxx Defendants.

ENTRY OF APPEARANCE with MOTION to File an Answer beyond the Reglementary Period COMES NOW, the defendant), through the undersigned counsel, to this Honorable Court, most respectfully submits this Entry of Appearance with Motion, and respectfully states that:

1. Upon receipt of the documents and files on 23 March 2019 by one of the xxx pertaining to xxx the handling interns noticed that no copy of the complaint was included and a motion to declare in default had already been filed and heard. 2. Defendant only knew of the case filed against her before the Court xxx after the she received by courier xxx

3. Defendant accordingly attended the hearing on 15 March 2019 without intent to disregard court processes and proceedings. Thereafter, she was referred to the Center for possible representation. 4. In this regard, the undersigned Center respectfully enters its appearance as counsel for xxx and requests that all pleadings, notices, orders, resolutions and other papers filed by the

plaintiff xxx issued by this Honorable Court, or otherwise intended for defendant xxx be sent to the undersigned firm at its address specified below. 5. Additionally, defendant implores the Honorable Court to allow her to submit her Answer on 05 April 2019 to the Complaint even beyond the reglementary period through the interest of justice with no intent to delay on her part, so that she may be able to ventilate her legal defenses (Hernandez v. Agoncillo, G.R. No. 194122). 6. The instant Entry of Appearance with Motion is filed in good faith, and is neither meant to interpose delay in the proceedings of this case nor prejudice the right of the complainant. PRAYER WHEREFORE, the defendant respectfully prays that the Honorable Court to admit the Answer filed by the defendant xxx on the date mentioned above. Other just and equitable reliefs are also prayed for. Conforme: xxx Defendant