MOTION FOR EXTENSION OF TIME TO FILE Responsive Pleading (Makilala Case)

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Republic of the Philippines

OFFICE OF THE OMBUDSMAN


OFFICE OF THE DEPUTY OMBUDSMAN FOR THE MILITARY
AND OTHER LAW ENFORCEMENT OFFICES
3rd Floor, Ombudsman Bldg. Agham Road
Diliman, Quezon City 1104 Philippines

KABUNGSUAN YADAO MAKILALA,


Complainant,

OMB.P-C-12-0607
For: Viol. Of RA 9184, Secs.37-38,
Art. XI, Secs. 3(e), (j) RA 3019, Art.
Art. 208, RPC, Secs. 4 (a), (b), (c),
(g), RA 6713.

OMB.P-A-12-0609
ACTING DIR. GAUDENCIO S. For:Grave Misconduct,Serious
PANGILINAN, ET. AL Dishonestly,Conduct Prejudicial
Acting Director GAUDENCIO S. PANGILINAN , And Gross Insubordination
Consultant and Chief of Staff VENANCIO G.
SANTIDAD, OIC Asst. Director TEODORA M.
DIAZ, BAC Chairman ALFREDO C. BENITEZ,
BAC Secretariat Head LARRY A. HARI, and
BAC-TWG Head LIGAYA A. DADOR ,
Public Respondents,

MEYER’S FOODS AND SERVICES, INC.,


as represented by its incorporators/directors or
responsible officers, namely, FLORDELIZA A.
VASQUEZ, JOSELITO C. VASQUEZ,
ELEONOR V. RETA , FLORESITA A. CABRERA, and
RICARDO F. CABRERA, MARINOLD GRILL CO., as
Representative by CLEOPATRA T FERRER, and
ARNULFO J. VICUNA, and MANG KIKO CATERING
SERVICES, INC., as representative by its incorporator/
directors or responsible officers, namely, REYNALDO
R. SY, ABNER H. NICDAO, ANTONIO T. BENEDICTO,
ARMANDO J. UMPACAN, and ERNEST REYNALDO G. DY
Private Respondants.
X- - - - - - - - - - - - - - - - - - - - - - - - - - - - - X
MOTION FOR EXTENSION OF TIME TO FILE REJOINDER

COMES NOW the private respondent, Meyer’s Foods and Services,


Inc., and unto this HONORABLE COURT, respectfully moves:

1. That the private respondent received the Private Complainant’s


Reply-Affidavit on December 18, 2012 and it has ten (10) days or
until December 28, 2012 within which to file its Rejoinder;

2. That due to the advent of the Christmas season and of celebration


of the holidays, private respondent’s legal counsel for the above-
captioned case had gone for a vacation in Mindoro and he shall be
back in Manila only on December 30, 2012 and he will need time
to prepare the Rejoinder;

3. That defendant moves for an additional period of fifteen (15) days


within which to file its Rejoinder;

4. That this motion is not intended to delay the instant proceedings


but for the sole reason stated herein.

WHEREFORE, premises considered, it is respectfully prayed of this


HONORABLE COURT that:

1. This motion be granted by the Honorable Court; and

2. That private respondent be given an additional period of fifteen


(15) days from December 28, 2012 or until January 12, 2013
within which to file their Rejoinder.

December 27, 2012. Sampaloc, Manila, Philippines.

FLORDELIZA A. VASQUEZ
Meyer’s Foods and Services, Inc.
Private Respondent
Notice of hearing

Hon.Director Dennis L. Garcia


Director
OMB, Quezon City

Attention: Kabungsuan Yadao Makilala

Please be advised that the above Motion is submitted for the consideration and
approval of the above Hon. Director Dennis L. Garcia immediately upon receipt or
the most convenient time of the same Officer without need of further argument
and presence of the undersigned private respondent.

FLORDELIZA A. VASQUEZ

EXPLANATION

A copy of the foregoing Motion was served to the private complainant


through registered mail. Personal service being impracticable due to distance,
time constraint and lack of personnel to effect personal service.

FLORDELIZA A. VASQUEZ

Copy Furnished:

Kabungsuan Yadao Makilala


Lower Makabuhay, NBP Reservation
Muntinlupa City

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