Motion For Extension of Time: WHEREFORE, Plaintiff Respectfully Prays That She Be
The plaintiff's counsel is requesting a 15-day extension to file a Reply to the defendant's Answer, which is currently due on January 20, 2014. The counsel has a tremendous workload with other urgent legal work that requires daily court appearances and document preparation. The extension is needed due to the counsel's heavy workload and is not intended to delay the case, but rather allow more time to adequately prepare the Reply.
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Motion For Extension of Time: WHEREFORE, Plaintiff Respectfully Prays That She Be
The plaintiff's counsel is requesting a 15-day extension to file a Reply to the defendant's Answer, which is currently due on January 20, 2014. The counsel has a tremendous workload with other urgent legal work that requires daily court appearances and document preparation. The extension is needed due to the counsel's heavy workload and is not intended to delay the case, but rather allow more time to adequately prepare the Reply.
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MOTION FOR EXTENSION OF TIME
COMES NOW,the plaintiff,through the undersigned counsel in
the above-entitled case and unto this Honorable Court respectfully states that: 1. He has been required to file a Reply to defendants Answer on20 January 2014; 2. The undersigned counsel, however, anticipates his inability to file the Reply on or before said due date because of the tremendous pressure of other equally urgent professional work requiring the preparation of pleadings and almost daily trial appearances before the various courts within and outside Baguio City. For this reason, the undersigned is constrained to ask for an additional fifteen (15) days from 20January 2014 within which to submit the plaintiffs Reply; 3. This motion is not intended for delay but is motivated only by the foregoing reason. WHEREFORE, plaintiff respectfully prays that she be granted fifteen (15) days from 20 January 2014 to submit plaintiffs Reply. Baguio City,