REPUBLIC OF THE PHILIPPINESNATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT_____ CITYBranch ___

IN THE MATTER OF THE AD HOC ARBITRATION BETWEEN

REPUBLIC OF THE PHILIPPINES represented by _________________,

Petitioner,

-versus- SP PROC Case No. _____

__________________,Respondent/s.

x------------------------------------------x

MOTION FOR ADDITIONAL EXTENSION OF TIME TO FILE _______

Petitioner, REPUBLIC OF THE PHILIPPINES, represented by _________, through the Office of the Solicitor General (OSG), respectfully states:

1. On [date], undersigned counsel previously filed a Motion for Extension of Time to File [pleading], requesting for an additional period of [__ days] from [due] or until [new due] within which to prepare and file the ______.

2. A draft of the required pleading is currently being prepared. However, in view of ______________, the _______ may not be filed on its due date.

3. The undersigned humbly asks for the indulgence of the Honorable Court, and respectfully requests for an additional period of ____ days from ____, or until _____ to prepare and file ______.

4. This motion is not intended to delay the proceeding, but is filed due to the foregoing reason.

PRAYER

Motion for Additional ExtensionRP v Arbitral Tribunal/____ Page 2 of 2SP PROC Case No. _________________

WHEREFORE, undersigned counsel respectfully prays for an additional period of ten (10) days from 24 March 2016, or until 3 April 2016 to prepare and file the Reply.

Makati City for Makati City, 23 March 2016.

Solicitor GeneralRoll No.

IBP Lifetime No. MCLE Exemption No.V- ; 12-03-2015

Assistant Solicitor General

IBP Lifetime No. ; Roll No. MCLE Exemption No.V- ; 10-01-2015

OFFICE OF THE SOLICITOR GENERAL134 Amorsolo St., Legaspi Village, Makati City

Email Address: docket @osg.gov.phTelephone No.: 8127980

COPY FURNISHED:

EXPLANATION(Pursuant to Rule 13, Section 11 of the 1997 Rules of Civil Procedure)

The foregoing Motion for Additional Extension of Time to File Reply is being filed and served through registered mail, personal service being impracticable due to lack of personnel.

-----------Assistant Solicitor General

LCL/24.mar.16