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Motion To File Belated Answer Sample

1) The motion requests permission to file a belated answer on behalf of the defendants in a civil case regarding recovery of possession with damages and a preliminary injunction. 2) The court previously granted a 30 day extension to file the answer, setting the deadline on May 16, 2023. However, the answer was not submitted by this date for an unspecified reason. 3) Copies of the answer were mailed to the plaintiffs on May 16th via registered mail. The motion apologizes for any inconvenience caused to the court or plaintiffs by the belated filing.

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152 views

Motion To File Belated Answer Sample

1) The motion requests permission to file a belated answer on behalf of the defendants in a civil case regarding recovery of possession with damages and a preliminary injunction. 2) The court previously granted a 30 day extension to file the answer, setting the deadline on May 16, 2023. However, the answer was not submitted by this date for an unspecified reason. 3) Copies of the answer were mailed to the plaintiffs on May 16th via registered mail. The motion apologizes for any inconvenience caused to the court or plaintiffs by the belated filing.

Uploaded by

konvan
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
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Republic of the Philippines

First Judicial Region


Municipal Trial Court in Cities
Baguio City
Branch 6

_______________________ Civil Case __________


Plaintiffs,

For:

Recovery of Possession
with Damages and Prayer for
Issuance of Preliminary
Injunction
____________________________
Defendants.
X-------------------------------------------------X

MOTION TO FILE BELATED ANSWER


WITH APOLOGY

WITH ALL DUE RESPECT TO THE HONORABLE COURT,


the undersigned Counsel most respectfully alleges and state that:

1. On April 17, 2023, this Honorable Court granted the undersigned


counsel’s prayer for thirty (30) days period of extension to file
answer, and ordered the defendants to file answer on or before
May 16, 2023;

2. However, defendants’ answer has not been submitted on said date


for the reason that _______________________;

3. Copies of defendants’ answer at any rate were mailed to the


Plaintiffs through Registered Mail on the said date;

4. Hence, this belated submission;

5. The undersigned counsel neither intended to delay the proceedings


of this Honorable Court nor to hinder the early administration of
justice;
6. In the light of the foregoing, and in the name of substantial justice,
the undersigned counsel respectfully begs for apologies for such
inconvenience unto this Honorable Court and the Plaintiffs.

PRAYER

WHEREFORE, premises all duly considered, it is most respectfully


prayed of this Honorable Court to note this motion and admit the belatedly
filed answer of the undersigned counsel to serve substantial justice not only
to the Plaintiffs but also to the Defendants of this case.

Such other relief just and equitable under the premises are likewise
prayed for.

Baguio City, Philippines, this 17th day of May, 2023.

Respectfully submitted.

________________________
Counsel for the Defendants
PTR No. ____________________
IBP No. 281426; 01-0710-2023; B.C
R0LL No. ________; 05-29-2017; Mla.
MCLE Compliance No. VII-0021319; Valid until 04-14-2025
Yandoc St., Baguio City, Philippines

NOTICE

THE BRANCH CLERK OF COURT


MTCC-6
Hall of Justice, Baguio City
Philippines

GREETINGS:

Please submit the foregoing pleading for the kind consideration and
approval of the Honorable Court immediately upon receipt hereof.

Thank you.

_____________________________
Copy furnished:

ATTY. _____________________
Baguio City

EXPLANATION

Copies of the foregoing answer were furnished to the counsel for the
plaintiffs via registered mail due to the distance and lack of office personnel
thereby making personal service cumbersome.

____________________________

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