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    MOTION - Extension of Time

    Uploaded by

    Jeff Sarabusing
    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.

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    MOTION - Extension of Time

    Uploaded by

    Jeff Sarabusing
    105 views3 pages
    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.

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    MOTION - Extension of Time jeffsarabusing.wordpress.com

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    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.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    105 views3 pages

    MOTION - Extension of Time

    Uploaded by

    Jeff Sarabusing
    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.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 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

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