(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.

PRAYER

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