(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 whichto submit Defendant's
Answer or Responsive Pleading. Moreover, this additional time will also allow
the undersigned tointerview 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