Republic of the Philippines

National Capital Judicial Region

Regional Trial Court
Br. ____

PEOPLE OF THE PHILIPPINES

Plaintiff,

CRIM. CASE NO.

-versus-
_________________________

_______________________________
Accused.
x-----------------------x

Motion for Extension of Time to File Memorandum

COMES NOS, Accused through the undersigned counsel, to this

Honorable Court, most respectfully avers that:

1. Accused is given thirty (30) days to file his Memorandum

which is due on the 27 December 2019.

2. Unfortunately, due to pressure and volume of work, coupled

with upcoming Christmas day and New Year’s, the undersigned counsel
cannot submit the Memorandum on 27 December 2019.

3. For this reason, undersigned counsel needs an additional period

of fifteen (15) days from 27 December 2019 within which to file their
Memorandum.

4. This motion is not in any way intended to delay the early

resolution of this case but is sought solely on account of the reasons stated
above.

Prayer
WHEREFORE, premises considered, it is respectfully prayed of this
Honorable Court that Accused be given an additional period of FIFTEEN
(15) days from 27 December 2019, within which to file his Memorandum.
 Such other relief and remedies as may be available under the
circumstances are, likewise, prayed for.

City of Malolos, Bulacan for Pasay City, 23 December 2019.

_______

By:

_____________

Notice

The Clerk of Court

Regional Trial Court
Pasay City
Branch _____

Greetings!

Kindly submit the foregoing Motion for Extension of Time to File

Memorandum for the consideration of the Honorable Court immediately
upon receipt thereof without further arguments and appearance of counsel.

________________________

Notice & Copy Furnished

Copy Furnished by Registered Mail:

____________

Please be notified that the foregoing Motion for Extension of Time to

File Memorandum is being submitted for the consideration and approval of
the Honorable Court immediately upon receipt thereof without further
arguments and appearance of counsel.

___________________

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 Explanation per Section 11, Rule 13 of the 1997 Rules of Court

This is to certify that a copy of the above pleading is being filed and/or
served by registered mail due to time constraints and the lack of necessary
personnel to effect filing and/or service by hand.

_______________

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