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Motion For Extension of Time To File Answer

The defendant's counsel has filed a motion requesting a 15-day extension to file an answer in response to a civil case regarding legal redemption and damages. The defendant only engaged the counsel on September 10th, with the original deadline to file being September 12th. Due to the pressures of other work and commitments, the counsel claims they will not have sufficient time to study the defense and prepare an answer if not given more time. The motion is not intended to delay the case, but solely to allow the counsel additional time to prepare the answer and interview witnesses.

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17K views2 pages

Motion For Extension of Time To File Answer

The defendant's counsel has filed a motion requesting a 15-day extension to file an answer in response to a civil case regarding legal redemption and damages. The defendant only engaged the counsel on September 10th, with the original deadline to file being September 12th. Due to the pressures of other work and commitments, the counsel claims they will not have sufficient time to study the defense and prepare an answer if not given more time. The motion is not intended to delay the case, but solely to allow the counsel additional time to prepare the answer and interview witnesses.

Uploaded by

Mai pee
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

8th Judicial Region


REGIONAL TRIAL COURT
BRANCH 10
Abuyog, Leyte

REMEDIOS A. ARIATE, Rep. CIVIL CASE NO.: 801


by LOLITO A. LLENO,
Plaintiff, FOR: LEGAL REDEMPTION
with DAMAGES, etc.
-versus-

Sps. EDNA Z. BLAZO and


JULIUS B. BLAZO,
Defendants.
x----------------------------------------x

MOTION FOR EXTENSION OF TIME TO FILE ANSWER

DEFENDANT, by the undersigned counsel, and unto this


Honorable Court, most respectfully states that:

1. Defendant engaged the services of undersigned counsel only on


September 10, 2019;

2. Defendant was served with Summons and copy of the Complaint on


August 28, 2019 and thus has until September 12, 2019 within which
to submit an Answer or Responsive Pleading;

3. However, the time remaining and due to the pressures of equally


urgent professional work and prior commitments, the same is not
sufficient in order for the undersigned counsel to study our defense and
prepare an answer thus, she will not be able to meet the said deadline;

4. As such, undersigned counsel is constrained to request for an


additional period of Fifteen (15) 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.

1
PRAYER

WHEREFORE, Defendant most respectfully prays of this Honorable


Court that he be given an additional period of Fifteen (15) Days from
today within which to submit an Answer or other Responsive Pleading.

Other relief just and equitable are likewise prayed for.

Tacloban City, Philippines, September 10, 2019.

ATTY. MA. CHRISTINA ERNEST U. MOLINA


Counsel for the Defendants
0977 R. Mendiola St., Brgy. Sta Cruz,
Palo, Leyte, Philippines 6501
Contact No. 09173217334
Roll of Attorneys No. 72489/06-14-19
IBP No. 089047/06-10-19, Leyte Chapter
PTR No. PL 7904947/07-24-19, Tacloban City
MCLE Compliance – On process August 2019

NOTICE OF HEARING AND COPY FURNISH

THE BRANCH CLERK OF COURT


REGIONAL TRIAL COURT
Branch 10
Abuyog, Leyte

ATTY. MARIA SHEILA DELOSO-BAQUILOD


Counsel for the Plaintiff
PUBLIC ATTORNEY’S OFFICE
Abuyog District Office
Brgy. Loyonsawang, Abuyog, Leyte

GREETINGS:

Kindly submit the foregoing Motion for Extension of Time to File


Answer for the consideration and approval of the Honorable Court
immediately upon receipt hereof.

ATTY. MA. CHRISTINA ERNEST U. MOLINA


Counsel for the Defendants

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