Motion For Estension To File Answer.docx

Republic of the Philippines REGIONAL TRIAL COURT 7th Judicial Region BRANCH 5 Cebu City

Civil Case No. _______ To be edited

For: SPECIFIC Plaintiffs,

PERFORMANCE WITH DAMAGES

-versus-

To be edited, Defendant. x- - - - - - - - - - - - - - - - - - - - - - - - x

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 April 3, 2018; 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 30 days 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. PRAYER WHEREFORE, Defendant most respectfully prays of this Honorable Court that he be given an additional period of 30 days from today within which to submit an Answer or other Responsive Pleading.

Other relief just and equitable are likewise prayed for. Cebu City, Philippines. (to be edited), 2019.

IPIL MOSLARES AND COSTELO LAW OFFICES Counsel for the Defendant P. Del Rosario St., Cebu City Tel: (035) 226 2220 / (035) 422 7783

ATTY. CAREYSSA MAE I. IPIL NOTARY PUBLIC Not. Comm. 03-2018 Cebu City, Valid until Dec. 12, 2019 Roll No. 47880 TIN 216-823-327 IBP Lifetime No. 2863/03-06-14/ PPLMPM, MM. MCLE Comp. No. V-0008649/04/15/16 to 04/14/19 PTR No. 1163275-12/ 01-08-18 Cebu City