…….HONORABLE JUDGE
…….
CASE NUMBER: …….
MOTION TO EXTEND THE DEADLINE
THE DEFENDANT STATES THE FOLLOWING: ……..
ROLE: …….
PLAINTIFF: …….
ROLE: …….
SUBJECT: We Request an Extension of the Response Period for the Case.
EXPLANATIONS: 1- The complaint filed by the plaintiff coincides with. Two days prior to the hearing date… the hearing date has been notified.
2- We have not had sufficient time to investigate the case and the related events that are the subject of the petition submitted to us by our client.
3- Our client has not yet provided us with the power of attorney necessary for us to prepare our defense against the lawsuit. Pursuant to Article 197 of the Code of Civil Procedure, we request that a reasonable extension of time be granted to us.
DEFENDANT’S COUNSEL