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Sample Motion For Extension of Time

Plaintiff Juan de la Cruz filed a motion for extension of time to file a reply to defendant Cosing Gaw Loo's answer. Plaintiff's counsel requests an additional 15 days, until August 14, to submit the reply due to the pressure of other legal work and daily trial appearances resulting from court backlogs caused by the COVID-19 quarantine. The motion is not intended for delay but to allow sufficient time for preparation given these circumstances.

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2K views

Sample Motion For Extension of Time

Plaintiff Juan de la Cruz filed a motion for extension of time to file a reply to defendant Cosing Gaw Loo's answer. Plaintiff's counsel requests an additional 15 days, until August 14, to submit the reply due to the pressure of other legal work and daily trial appearances resulting from court backlogs caused by the COVID-19 quarantine. The motion is not intended for delay but to allow sufficient time for preparation given these circumstances.

Uploaded by

Irin200
Copyright
© © All Rights Reserved
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

FIRST JUDICIAL REGION


REGIONAL TRIAL COURT
Branch 39, Quezon City

JUAN DE LA CRUZ,
Plaintiff,
Civil Case No.: 920813
-versus-
For: DAMAGES
COSING GAW LOO,
Defendant.
x---------------------------------x

MOTION FOR EXTENSION OF TIME

PLAINTIFF, by counsel, respectfully states that:


(1) He has been required to file a Reply to defendant’s Answer by 31 July 2020;
(2) The undersigned counsel, however, anticipates his inability to file the Reply on or before
said due date because of the tremendous pressure of other equally urgent professional
work requiring the preparation of pleadings and lately, the almost daily trial appearances
before the various courts within and outside Metro Manila as a result of the backlogs
caused by the more than 100 days of quarantine to contain the COVID-19 pandemic. For
this reason, the undersigned is constrained to request for an additional fifteen (15) days
within which to submit the plaintiff’s Reply;
(3) This motion is not intended for delay but is motivated only by the foregoing reason.

WHEREFORE, plaintiff respectfully prays that he be granted additional fifteen (15)


days from 31 July 2020, or until 14 August 2020, within which to submit plaintiff’s Reply.

Quezon City, Philippines; 18 July 2020.

ATTY. CEPHEUS I. QUIÑONES


Counsel for the Plaintiff
8F Winner Bldg, Diliman, Quezon City
PTR No. 88888; 01/04/2020; Quezon City
IBP OR No: 6928764; 01/04/2020; Quezon City
Roll No.: 81319; 04/08/2005
Quezon City, Philippines
TIN No. 143-888-434-000

Copy furnished:

ATTY. BONGGA GO
Counsel for the Defendant
123 Calamansi Street,
Diliman, Quezon City

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