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Legtech 3G Motion For Extension

The defendant's counsel files a motion for extension, requesting an additional 15 days to submit an answer or responsive pleading on behalf of the defendant. Counsel was engaged only 5 days ago and was then hospitalized due to COVID-19 symptoms, preventing counsel from studying the complaint's allegations within the initial response period. The motion is filed due to these circumstances and not for purposes of delay.

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Kim Ydela Lumagbas
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49 views1 page

Legtech 3G Motion For Extension

The defendant's counsel files a motion for extension, requesting an additional 15 days to submit an answer or responsive pleading on behalf of the defendant. Counsel was engaged only 5 days ago and was then hospitalized due to COVID-19 symptoms, preventing counsel from studying the complaint's allegations within the initial response period. The motion is filed due to these circumstances and not for purposes of delay.

Uploaded by

Kim Ydela Lumagbas
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

LEGTECH 3G

LUMAGBAS, Kim Ydela E. September 10, 2020


2017-400284

MOTION FOR EXTENSION

DEFENDANT, by the undersigned counsel, and unto this Honorable Court, most respectfully states that:

1. Defendant engaged the services of undersigned counsel only on September 5, 2020;

2. Defendant was served with Summons and copy of the Complaint on August 26, 2020 and thus has
until September 10, 2020 within which to submit an Answer or Responsive Pleading;

3. However, due to the manifestation of COVID-19 symptoms of the undersigned counsel (premise), the
same was admitted in the ICU unit of the hospital and was unable to study the allegations of the
complaint (conclusion);

4. As such, undersigned counsel is constrained to request for an additional period of 15 days from today
within which to submit Defendant's Answer or Responsive Pleading;

5. This Motion is not intended for delay but solely due to the foregoing reasons.

PRAYER

WHEREFORE, Defendant most respectfully prays of this Honorable Court that he be given an additional
period of 15 days from today within which to submit an Answer or other Responsive Pleading.

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