(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 which to submit Defendant's
Answer or Responsive Pleading. Moreover, this additional time will also allow
the undersigned to interview 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
 REPUBLIC OF THE PHILIPPINES
METROPOLITAN TRIAL COURT
City of Manila
Branch 1

TULFO DELA CRUZ,

Plaintiff,
CIVIL CASE No. 12345
-versus- FOR: Collection of Sum of Money
RAYMART REYES,
Defendant.
x----------------------------------------------------x

ENTRY OF APPEARANCE

THE BRANCH CLERK OF COURT

Metropolitan Trial Court
City of Manila - Branch 1

Please enter appearance of the undersigned as counsel for the defendant RAYMART
REYES, with his express conformity as indicated below, in this case. Henceforth, kindly
address all pertinent notices to the undersigned at the address given below.

RESPECTFULLY SUBMITTED.

City of Manila, Philippines, September 25, 2012.

CRUZ AND TOLENTINO LAW OFFICE

Counsel for the
Defendant
Suite 405 Elizabeth Center
Ermita, Manila

By:
Jean Pierre Guidotti
Roll No. 23456
IBP No. 22345/1-3-12/Manila
PTR No. 33456/1-3-12/Manila

With conformity:
RAYMART REYES

Copy furnished:
FRETTI LAUREL
Counsel for the Plaintiff
Unit 1234 Laurel Building
Sampaloc, Manila