(to Set Aside Order of Default and to Admit Attached Answer)
COMES NOW DEFENDANTS, by the undersigned counsel, unto this Honorable
Court, respectfully aver:
1. Pre-trial in the above-captioned case was set on
2. By the time the undersigned counsel
3. In the interest of substantial justice, the __________ respectfully moves for a
reconsideration of the _______ Order issued by the Honorable Court dismissing the case. ________ would like to manifest to the Honorable Court their apologies for not arriving during the scheduled hearing
4. Furthermore, Section 4 of Rule 18 of the Revised Rules of Civil Procedure
leaves to the sound discretion of the Honorable Court as to whether or not a valid and justifiable ground exists to excuse a party from being absent.
5. Defendants thus pray that ___________ be allowed and _______ be reconsidered
in the belief that they have a meritorious case which deserves the consideration of the Honorable Court, coupled by the fact that the same has been unresolved for a long period of time 6. This Motion is interposed for the above-stated reasons and not to unduly delay the proceedings of this case.
WHEREFORE, the undersigned hereby pleads for the indulgence of this
Honorable Court that the said Order be reconsidered in the interest of substantial justice and in the spirit of humanitarian consideration.
Other just and equitable reliefs are also prayed for.