Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch 235, Makati

_______
Petitioner,

- versus - Civil Case No. ______

For: _______

______
Respondent.
x-- -- -- -- -- -- -- -- -- -- -- -- -- --x

MOTION FOR EXTENSION OF TIME

DEFENDANT, ______, through the undersigned counsel, and

unto this Honorable Court, respectfully states that:

1. On ___________, Defendant received a copy of the

Summons dated ___________, requiring it to file their answer to the
attached complaint dated ___________, within thirty (30) days from
receipt thereof, or until ___________

2. In conjunction, Rule 11, Section 11 of the Revised Rule of

Court states that:

“A defendant may, for meritorious reasons, be

granted an additional period of not more than thirty (30)
calendar days to file an answer. A defendant is only
allowed to file one (1) motion for extension of time to file
an answer.

x x x.” (Omissions supplied)

3. As applied to the instant case, the Defendant most

respectfully requests this Honorable Court to grant it an additional
thirty (30) days from ___________within which to file its answer,
considering that the undersigned Law Office has just been recently
engaged by the Defendant; the case requires the verification of
alleged numerous transactions by the Plaintiff from 2018 up to 2021
and all other compilation of defenses the defendant may have.
Hence, undersigned counsel has no sufficient time to prepare the
Answer and the other Pleadings required to be submitted with it.

4. Accordingly, the undersigned begs the kind indulgence of

the Honorable Court to grant an additional thirty (30) days from
___________, or until ___________within which to file its answer.

5. This motion is filed solely for the foregoing reason and is

not intended to delay the proceedings in the instant case.

RELIEF

WHEREFORE, it is most respectfully prayed that Defendant be

given an additional period of thirty (30) days from 20 January 2023, or
until 19 February 2023 within which to file their Answer.

Other just and equitable reliefs are likewise prayed for.

Pasig City for Makati City 18 January 2023

LAW OFFICE
Counsel for the Defendant
Telephone:
Email: info@

By:

EXPLANATION

In compliance with Rule 13 of the Revised Rules of Civil

Procedure, this MOTION was served by registered mail due to time
and distance constraints to effect personal service, the filing of the
foregoing Motion was made by registered mail.