REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
BRANCH ______, _______________ CITY

________________________________,
Plaintiff,

-versus- Civil Case No. __________

For: ____________________

_________________________________,
Defendant.
x-----------------------------------------x

ENTRY OF APPEARANCE
with
MOTION FOR EXTENSION OF TIME TO FILE ANSWER
DEFENDANT, through the undersigned Public Attorney and unto this
Honorable Court, most respectfully states:

1. That defendant sought the assistance of the undersigned counsel and she
deemed it proper to represent him/her and is hereby respectfully entering its
appearance as counsel for the defendant;

2. Henceforth, it is respectfully prayed that copies of all pleadings, notices,

decisions and other legal processes be sent to the undersigned counsel at the
address indicated below;

3. On March 25, 2019, defendant received a copy of the summons requiring

him/her to file an Answer within 15 days from receipt of the notice. The last day
for filing an Answer is on April 09, 2019. Considering that the services of the
undersigned was just recently engaged to handle the instant case and has only
several days left to prepare and submit an Answer, hence, the undersigned would
need additional time to study the case and confer with the client to intelligently
prepare an Answer;

4. In view of the foregoing, the undersigned is constrained to request for an

additional period of fifteen (15) days from April 09, 2019 or until April 24, 2019,
within which to file an Answer;

6. This Motion is not intended for delay but solely for the reason stated
therein.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of the

Honorable Court that the Entry of Appearance of the undersigned counsel be duly
Noted and that the foregoing Motion for extension of Time be GRANTED; thus,
allowing defendants to file their Answer up until April 24, 2019.

Defendants likewise pray for other just and equitable relief apt for the
afore-stated circumstances.

This 8th day of April, 2019. __________________City, Metro Manila.

 By:

ATTY.__________________________
Address
Roll No. _______________
IBP Lifetime Member No. _____________
MCLE Compliance No. VI-____________________

ATTY. ____________________________
Branch Clerk of Court
RTC, Branch ______
______________, Metro Manila

Greetings:

Please take notice that the foregoing Motion is submitted for the
consideration and approval of the Honorable Court immediately upon receipt
hereof

ATTY. ______________________

COPY FURNISHED:

ATTY. ______________________
Counsel for the Plaintiff
Address

EXPLANATION

The foregoing Entry of Appearance with Motion for Extension of Time is

being served thru registered mail for lack of messenger to effect personal service.

ATTY. __________________________