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MOTION FOR LEAVE TO AMEND ANSWER
COMES NOW the defendant, by the undersigned counsel, and unto this Honorable Court, respectfully moves for leave to amend his ANSWER already filed, dated ____________, 2004, and for this purpose hereby presents the attached AMENDED ANSWER, wherein the amendments sought to be incorporated are indicated by being underscored.
WHEREFORE, in order that the real matter in dispute and all matters in this action may be completely determined, it is respectfully prayed that the attached AMENDED ANSWER be admitted.
Muntinlupa City, __________________, 2004.
Counsel for Defendant
(Address, IBP & Roll No. )
NOTICE OF HEARING
TO : Attorney for Plaintiff
Sir: Please take notice that on Friday, __________, 2004, at 2:00 P.M. or as soon thereafter as counsel may be heard, the undersigned attorney will ask the Regional Trial Court of Muntinlupa to grant the foregoing motion.
Counsel for Defendant
COPY RECEIVED:
Attorney for Plaintiff
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