Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch 13, Makati City

OGIE RIVERA VALENCIANO,

Defendant,

Civil Case No. 12345

For: Copyright Infringement
With Damages

- versus -

PHILIPPINE INSTITUTE OF
COMPOSERS, AUTHORS AND
PUBLISHERS, INC,
Plaintiff,
x------------------------------------------------x
MOTION FOR EXTENSION OF TIME
TO FILE PLEADING

Defendant, by counsel, respectfully alleges that:

1. On August 22, 2015, he received a copy of the plaintiff's Complaint dated August 19,
2015, received by the companys security guard. Hence, pursuant to the Rules on Civil
Procedure , defendant shall file his answer to the complaint within fifteen (15) days after
service of summons, unless a different period is fixed by the court. Defendant therefore,
has until September 6, 2015 within which to file its Answer to the same;
2. However, due to volume and pressure of work, business trips abroad, coupled with
other equally important and urgent professional commitments, the undersigned counsel
cannot complete the said Answer within the period required and will need an additional
five (5) days from September 6, 2015 or until September 11, 2015 within which to do so;
3. This motion is being filed due to the reason above-stated and not for the purpose of
delaying the instant case.
WHEREFORE, defendant prays that he be granted an additional five (5) days from
September 6, 2015 or until September 11, 2015 within which to submit an Answer.
Makati City, Philippines. September 2, 2015.
ATTY KREMLIN SANTOS
Counsel for Defendant

NOTICE OF HEARING

THE BRANCH CLERK OF COURT

RTC - Branch 13
Makati City
Greetings!
Kindly submit the foregoing motion for consideration and approval of this Honorable
Court immediately upon receipt hereof.

ATTY KREMLIN SANTOS

Copy furnished by registered mail:
ATTY JERICHO RESUBAL
Counsel for the Plaintiff
Garden Level, Corinthian Plaza, Paseo de Roxas, Makati City

Please take notice that counsel has requested for the approval of this motion
immediately upon receipt.
ATTY KREMLIN SANTOS