Republic of the Philippines

____________ Judicial Region

________________ TRIAL COURT

Branch _____, _____________, _____________

MOTION FOR EXTENSION OF TIME

TO FILE COMMENT TO OFFER OF EVIDENCE

Defendant, by counsel, respectfully alleges that:

1. On August 3, 2013, he received a copy of the plaintiff's Offer of Evidence dated July 25, 2013. Hence, pursuant to the order of the Honorable Court in open court during the July 22, 2013 hearing, defendant has five (5) days or until August 8, 2013 within which to file its Comment to the same;

2. However, due to volume and pressure of work, coupled with other equally important and urgent professional commitments, the undersigned counsel cannot complete the said Comment to the Offer of Evidence within the period required and will need an additional ten (10) days from August 8, 2013 or until August 18, 2013 within which to do so;

3. This motion is being filed due to the reason above-stated and not for the purpose of delaying the instant case.

WHEREFORE, defendant prays that he be granted an additional ten (10) days from August 8, 2013 or until August 18, 2013 within which to submit a Comment to the Offer of Evidence.

Quezon City, Philippines. August 30, 2013.

ATTY. ___________________________________

Counsel for Defendant

NOTICE OF HEARING

THE BRANCH CLERK OF COURT

RTC - Branch 39

Quezon City

Greetings!

Kindly submit the foregoing motion for consideration and approval of this Honorable Court immediately upon receipt hereof.

___________________________________

Copy furnished by registered mail:

ATTY. AB CD

Counsel for the Defendant

2233 Zamora Street, Pasay City

Please take notice that counsel has requested for the approval of this motion immediately upon receipt.

___________________________________