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SECOND MOTION FOR EXTENSION OF TIME TO FILE

POSITION PAPER AND ENTRY OF APPEARANCE OF
COUNSEL

Comes now, complainant, through the undersigned counsel,

respectfully avers, that:

1. On February 16, 2017, complainant filed a motion for

extension, hereto attached as Annex “A”, for a period of 10
days or until February 16, 2017 to file his position paper;

2. On February 13, 2017, Complainant sought the services of

the undersigned counsel which was duly accepted;

3. In view of the foregoing, the undersigned counsel has only

three days to prepare the required position paper;

4. Complainant humbly asks for another extension of time of

ten (15) days or until March 3, 2017 to file his position
paper purposely to give the undersigned counsel ample time
to study the case and intelligently prepare the position
paper;

5. The undersigned counsel, for and in behalf of the

complainant, most respectfully enters her appearance in the
above-captioned case. Thus, it is most respectfully
requested that henceforth, any and all notices, orders,
resolutions and judgments by this Honorable Court be sent
to the address indicated below.

PRAYER

WHEREFORE, it is earnestly prayed before this Honorable

Office that complainant be given an extension of time of fifteen
(15) days from February 16, 2017 or March 3, 2017 to submit
his position paper and supporting documents and that
henceforth, any and all notices, orders, resolutions and
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judgments by this Honorable Office be sent to the address

indicated below.

Other reliefs, just and equitable under the circumstances,

are likewise prayed for.

February 16, 2017. Tagum City, Davao del Norte,

Philippines.