Motion for Extension of Time to File Comment
Republic of the Philippines
____________ Judicial Region
________________ TRIAL COURT
Branch _____, _____________, _____________
______________________,
Plaintiff,
-versus-
______________________,
Defendant.
x - - - - - - - - - - - - - - - - - - - - - - - - -x
Civil Case No ____________________
FOR: _____________________________
MOTION FOR EXTENSION OF TIME
TO FILE COMMENT TO OFFER OF EVIDENCE
Defendant, by counsel, respectfully alleges that:
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;
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;
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.
___________________________________