Republic of the Philippines
REGIONAL TRIAL COURT
National Capital Judicial Region
Branch 45, City of Manila
STEVE ROGERS,
Plaintiff,
Civil Case No. 12345
-versus- For: Sum of
Money
SUNRISE DEVELOPMENT CORPORATION
Defendant.
x-----------------------------------------------x
MOTION FOR EXTENSION OF TIME
TO FILE AN ANSWER
Defendant Sunrise Development Corporation (SDC), by counsel, states:
1. SDC’s Answer is due on May 7, 2020, after it received both the summons and a copy of
the Complaint on April 7, 2020. But since the matter has been referred to its counsel on
April 29, 2020, for representation, counsel needs added time to study the case and confer
with SDC’s officers as regards its defenses.
2. It is, consequently, constrained to ask for an additional 30 days from May 7, 2020, or
until June 6, 2020, within which to file its Answer.
ACCORDINGLY, SDC asks the Court for an extension of 30 days from June 7, 2020 or until
July 7, 2020 within which to file its Answer.
Other reliefs just and equitable are also asked for.
Manila, Philippines. May 5, 2020
(sgd.) ATTY. NATHANIEL
BONIFACIO
Counsel for Defendant
NOTE: A non-litigious motion, such as a motion for
Unit 1, Building X, Mendiola, Manila.
extension to file answer, “shall not be set for hearing and
Roll No. 12345
shall be resolved by the court within FIVE CALENDAR DAYS
IBP No. 123456:
from receipt thereon.
PTR No. 12456
MCLE I
MCLE II
Notice and Copy Furnished;
ATTY. SUNDAY S. DOMINGO
Counsel for Plaintiff Steve Rogers
(Address)
Madam:
Please take notice that the undersigned counsel shall submit the foregoing motion
for the Court’s resolution on May 8, 2020, Friday, at 2:00 PM.
(sgd.) ATTY. NATHANIEL
BONIFACIO
Counsel for Defendant
NOTE: Sec. 11, Rule 11 of the 2019 Amendments provides –
“Section 11. Extension of Time to File an Answer. – A defendant may, for meritorious reasons,
be granted an additional period of not more than 30 calendar days to file an answer. A
defendant is only allowed to file one motion for extension of time to file an answer.
A motion for extension to file any pleading, other than an answer, is prohibited and considered
a mere scrap of paper. The court, however, may allow any other pleading to be filed after the
time fixed by these rules.”