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Motion For Judgment On The Pleadings Sample
Motion For Judgment On The Pleadings Sample
1. On May 5, 2013, plaintiff sued defendant for a sum of money in the amount of Two Hundred
Thousand Pesos (P200,000.00);
2. In his Answer, defendant admitted the obligation and merely stated that he was asking to be
given an extension of time to pay his obligation but that plaintiff instead filed the Complaint;
3. Said Answer has not tendered any issue and in fact it can be read therefrom that defendant
admitted the obligation; consequently, a judgment on the pleadings may be rendered.
ATTY. VX YZ
Counsel for Plaintiff
NOTICE OF HEARING
ATTY. AB CD
Counsel for the Defendant
1234 Zamora Street, Pasay City
Greetings!
Please take notice that the undersigned counsel will submit the foregoing Motion to the
Honorable Court on August 27, 2013 at 8:30 in the morning for its favorable consideration and
approval.
VX YZ
ATTY. AB CD
Counsel for the Defendant
2233 Zamora Street, Pasay City
EXPLANATION
Due to lack of messengerial services to effect personal service, a copy of the foregoing motion
was sent to defendant's counsel through registered mail.
VX YZ