Scribd
Upload
227 views3 pages

MOTION - Extension of Time

1) The defendant filed a motion for extension of time to file an answer to the plaintiff's complaint for specific performance. 2) The defendant requests a 30 day extension because documents needed to support counterarguments are still unavailable from a government office due to COVID-19 quarantine restrictions. 3) A notice of hearing is included, setting the motion for a hearing on a future date according to revised court rules regarding notice of hearing requirements.

Uploaded by

Jeff Sarabusing
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
227 views3 pages

MOTION - Extension of Time

1) The defendant filed a motion for extension of time to file an answer to the plaintiff's complaint for specific performance. 2) The defendant requests a 30 day extension because documents needed to support counterarguments are still unavailable from a government office due to COVID-19 quarantine restrictions. 3) A notice of hearing is included, setting the motion for a hearing on a future date according to revised court rules regarding notice of hearing requirements.

Uploaded by

Jeff Sarabusing
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
You are on page 1/ 3

REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION


Regional Trial Court, Branch ____
Pasay City

AAA BBB,
Plaintiff,

-versus- Civil Case No. ____


For: Specific Performance

XXX YYY,
Defendant.

x---------------------x

MOTION FOR EXTENSION OF TIME

Defendant, thru counsel, respectfully states that:

1. On 1 May 2020, a Complaint for Specific Performance was filed


against the Defendant before this Honorable Court;

2. On 3 May 2020, summons was served on the Defendant as


evidenced by the Sheriff’s Return on 3 May 2020, a copy of which is
attached as Annex “A”;

3. According to the Rules, a Defendant has only 15 days from the


receipt of the Complaint as reglementary period upon which he may file his
Answer;

4. As of this date, 14 May 2020, the Defendant is still in the process


of retrieving the documents from the government office. These documents
will support his counter-arguments in the Complaint;

5. As of this date, 14 May 2020, the government office is still unable


to deliver the documents to the Defendant in view of the COVID-19
Enhanced Community Quarantine; and,

6. Under the Rules, a Defendant may file an extension of time to file


an Answer under the grounds enumerated therein.

PRAYER

WHEREFORE, premises considered, Defendant respectfully prays


before this Honorable Court that he be allowed to extend the time for the
filing of his Answer for 30 more days.

Other reliefs just and equitable are likewise prayed for.

14 May 2020, Pasay City.

1
(sgd.)
Atty. XXX COUNSEL
Counsel for the Defendant
Address:
Phone Number:
E-mail Address:
Roll No:
IBP:
PTR:
MCLE:

NOTICE OF HEARING

Branch Clerk of Court


Regional Trial Court, Branch __
Pasay City

Atty. ____
Counsel for the Defendant, ___
Address

Greetings!

This motion is set for hearing on (date), (day), at (time). (Note the
change in the Notice of Hearing Requirement under the Revised Rules of
Court, which became effective 1 May 2020).

Atty. XXX COUNSEL


Counsel for the Defendant

Copy furnished:

Atty. ____
Counsel for the Plaintiff, ___
Address

EXPLANATION

A copy of this motion was served on the counsel for the Plaintiff via
registered mail due to lack of manpower. (If registered mail, or)

2
A copy of this motion was served on the counsel for the Plaintiff
through personal service. (If personal service. Attach affidavit of the
messenger + Jurat)

Atty. XXX COUNSEL


Counsel for the Defendant

You might also like

pFad - Phonifier reborn

Pfad - The Proxy pFad of © 2024 Garber Painting. All rights reserved.

Note: This service is not intended for secure transactions such as banking, social media, email, or purchasing. Use at your own risk. We assume no liability whatsoever for broken pages.


Alternative Proxies:

Alternative Proxy

pFad Proxy

pFad v3 Proxy

pFad v4 Proxy