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