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Republic of the Philippines

National Capital Judicial Region


Regional Trial Court of Makati
Branch 143

Motortrade Inc.
Respondent,

---versus----

Civil Case No. 123456


Petition for Partition

Kawasaki Inc
Defendant,

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 February 4,


2014;

2. Defendant was served with Summons and copy of the Complaint on January 22,
2014 and thus has until February 6, 2014 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 10 Days 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.

P R AYE R

WHEREFORE, Defendant most respectfully prays of this Honorable Court that he


be given an additional period of 10 Days from today within which to submit an
Answer or other Responsive Pleading.

Other relief just and equitable are likewise prayed for.


Cainta, Rizal Philippines, February 5, 2014

Amerie Prue Abad


Counsel
IBP No. 123456
PTR No. 123456
Abad Law Offices
Antipolo City

Averen Leigh Abad


Counsel
IBP No. 789456
PTR No. 789456
Abad Law Offices
Antipolo City

NOTICE OF HEARING

The Clerk of Court


RTC Branch 143
Makati City

Kindly submit the foregoing Motion for Extension of Time for the
consideration of the Court immediately upon receipt hereof.

Averen Leigh Abad

Gio Borje
Borje & Borje Law Offices
Cainta, Rizal

Please take notice that the foregoing Motion for Extension of Time is submitted for
the consideration of the Court immediately upon receipt hereof.

Averen Leigh Abad

EXPLANATION

Copies of this Motion for Extension of Time were filed and served by
registered mail to this Honorable Court and the private respondents, respectively,
due to lack of personnel and material time to effect personal service.

Averen Leigh Abad

Copies Furnished:
Gio Borje
Borje & Borje Law Offices
Cainta, Rizal