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Motion For Time - Cunningham
Motion For Time - Cunningham
1. On May 14, 2020, herein Respondent received a copy of the Decision rendered on
December 22, 2019 by this Honorable Office. A true copy of said Decision is hereto
attached and made integral part hereof as Annex “1”;
2. On this date, May 21, 2020, herein Respondent filed his Notice of Appeal with the
Regional Investigation and Detective Management Division (RIDMD), National Capital
Region Police Office (NCRPO), in connection with the aforesaid Decision;
3. Under the existing procedural rules and regulations, herein Respondent has a period
ten (10) days from receipt of said Decision, or until May 24, 2020, within which to file
the appropriate pleading, and other documents pertaining to his appeal with this
Honorable Office;
4. Being that the last day, May 24, 2020, falls on a Sunday, and due to the fact that
documents to be annexed to the appeal will take longer than the prescribed period to be
secured from the concerned government offices, Respondent now implores to this
Honorable Office that he (Respondent) be given an extension of TEN (10) more days
from May 24, 2020, or until June 3, 2020, within which to file his written appeal
memorandum/pleading;
5. This Motion is not intended to cause unnecessary delay in the resolution of the
foregoing case, but only due to the reason and urgency as aforestated, for which
Respondent seeks this Honorable Court’s kind understanding and consideration.
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WHEREFORE, it is most respectfully prayed of this Honorable Office that
Respondent be given an extension of TEN (10) more days from May 24, 2020, or until
June 3, 2020, within which to file his written appeal memorandum/pleading.
Herein Respondent prays for such other relief as this Honorable Office may deem just
and equitable under the premises.
RESPECTFULLY SUBMITTED.
VERIFICATION
That I, PAT WALTER A. CUNNINGHAM, of legal age, Filipino citizen, and with
postal address at No. 150 Nadurata St., 10th Avenue, Caloocan City, Metro-Manila, after
being duly sworn to in accordance with law, hereby depose and state, that I am the
Respondent in the above-entitled case, and I have caused the preparation of the instant
Notice of Appeal; I have read all the allegations therein and found the same to be true and
correct of my own personal knowledge, and/or based upon authentic documents;
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