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This document is a motion filed by defendant's counsel requesting a 15 day extension to file a responsive pleading in civil case number 8765-10 between plaintiff Zakee Ahmad Said and defendant Faiha Mohamad. The defendant's counsel argues they require more time due to their heavy workload and need to familiarize themselves with the facts of this case. They assert this motion is not intended to delay proceedings but to serve the interests of justice. The defendant's counsel notices both the court and plaintiff's counsel that the motion will be submitted for approval without need for an appearance or arguments, due to time constraints and the non-litigious nature of the request.

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Huzaimar Anjalin
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39 views

m4 Extension Time For Upload

This document is a motion filed by defendant's counsel requesting a 15 day extension to file a responsive pleading in civil case number 8765-10 between plaintiff Zakee Ahmad Said and defendant Faiha Mohamad. The defendant's counsel argues they require more time due to their heavy workload and need to familiarize themselves with the facts of this case. They assert this motion is not intended to delay proceedings but to serve the interests of justice. The defendant's counsel notices both the court and plaintiff's counsel that the motion will be submitted for approval without need for an appearance or arguments, due to time constraints and the non-litigious nature of the request.

Uploaded by

Huzaimar Anjalin
Copyright
© Attribution Non-Commercial (BY-NC)
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines REGIONAL TRIAL COURT OF LANAO DEL SUR 12th Judicial Region Marawi City ZAKEE

AHMAD SAID, Plaintiff, ---versus--FAIHA MOHAMAD, Defendant. X -------------------------------------X CIVIL CASE No. 8765-10

MOTION FOR EXTENSION OF TIME TO FILE RESPONSIVE PLEADINGS


Defendant, through the undersigned counsel and to this Honorable Court most respectfully alleges: 1. That the reglementary period to file responsive pleadings in the above-entitled case will expire on December 20, 2010, it being that defendant received the summons together with the copies of the complaint on December 1, 2010; 2. That due to the almost unbearable pressure of work saddling the undersigned counsel in preparing memoranda, briefs, petition, etc. in other equally important cases let alone the fact that he still has to acquaint himself of the facts and circumstances of the case, he is now constrained to ask more time within which to prepare and eventually file responsive pleadings for the defendant; 3. That this motion is not intended for delay but solely to serve the very ends of justice; WHEREFORE, it is most respectfully prayed of this Honorable Court that the herein defendant be given an extension of fifteen days from the expiration of the reglementary period or until January 10, 2011 within which to file said responsive pleadings. Further prays for other relief as may be deemed just and equitable under the premises. Marawi City, December 15, 2010.

Atty. HANJALIN HANJALIN Counsel for the Defendant Bo. Salam, MSU Campus-Marawi City IBP OR No. 12345678/1-10-10/ Marawi City PTR No. 064321/1-10-10/Marawi City Roll of Attorneys no. 12345, May 21, 1999 MCLE Compliance No. 1-10002 TIN No. 00012

NOTICE HEARING
THE CLERK OF COURT RTC-Branch 9 Marawi City GREETINGS: Due to time constraints and the non-litigious nature of the foregoing motion, kindly submit it for the consideration and approval of the Honorable Court immediately upon receipt hereof sans appearance and further arguments of the undersigned counsel.

Atty. HANJALIN HANJALIN

NOTICE HEARING
Atty. HUZAIMAR HUZAIMAR Counsel for the Plaintiff Biaba-Basak Marawi City GREETINGS: Please take notice that due to time constraints and the non-litigious nature of the foregoing motion, the same will be submitted for the consideration and approval of the Honorable Court immediately upon receipt hereof sans appearance and further arguments of the undersigned counsel.

Atty. HANJALIN HANJALIN

Copy furnished: Atty. HUZAIMAR HUZAIMAR Counsel for the Plaintiff Biaba-Basak Marawi City

EXPLANATION
I hereby certify that copies of this Motion for Extension of Time to File Responsive Pleadings were furnished the plaintiff by registered mail, it being that personal service is not feasible/practicable due to distance and lack of office personnel to effect personal service.

Atty. HANJALIN HANJALIN

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