REPUBLIC OF THE PHILIPPINES

FOURTH JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 83
TANAUAN CITY, BATANGAS

PEOPLE OF THE PHILIPPINES,

Plaintiff,
-versus- Crim. Case No. 07-06-3603
For: Murder
LEONARDO DE LEON y
ENDAYA, ET. AL.,
Accused.
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MOTION FOR EXTENSION OF TIME
TO FILE MEMORANDUM FOR ACCUSED

Accused, by counsel, most respectfully states:

1. Undersigned accepted and entered her appearance as counsel only on 10

April 2017, during the presentation of the prosecution’s presentation of
rebuttal evidence;

2. On even date, presentation of rebuttal evidence concluded and the private

prosecutor rest his case; as there being no sur-rebuttal on the part of
defense, the case now reached the end of trial;

3. Considering the same, the undersigned requested and was granted thirty
(30) days within which to submit memorandum for the defense;

4. However, considering that undersigned counsel handled the case at the

conclusion and upon perusal on records disclosed voluminous documents
and records in referenced to the case which undersigned needs to review
from onset of trial, as well as the heavy workload in other equally
important cases, the undersigned foresee the impossibility of filing the
same within said period;

5. In view thereof, undersigned counsel is constrained to request from this

Honorable Court an extension of ten (10) days or until 15 May 2017
within which to serve and file accused’ Memorandum;

6. The foregoing motion for extension of time is due solely to the aforesaid
reason and is not intended to delay the proceedings in this case.

PRAYER
 WHEREFORE, premises considered, accused Leonardo De Leon,
Christopher De Leon and Noli Mendoza most respectfully request an extension of
ten (10) days from 05 May 2017 or until 15 May 2017 within which to file
Accused’ Memorandum.

Accused further pray for other just and equitable remedies.

Tanauan City, Batangas, 05 May 2017.

PUBLIC ATTORNEY’S OFFICE

Tanauan City District Office
Counsel for the Accused
Hall of Justice Bldg., Tanauan City

By:

HEART C. LERO
Public Attorney I
Counsel for Accused
Roll No. 61581
Lifetime IBP No. 015726
MCLE Compliance No. V-0017604; 04.15.2016

THE HON. CLERK OF COURT

RTC, Branch 83
Tanauan City, Batangas

G R E E T I N G S:

Please submit the forgoing MOTION FOR EXTENSION OF TIME TO FILE

MEMORANDUM FOR ACCUSED for the utmost consideration of the Honorable Court
immediately upon receipt hereof.

HEART C. LERO

Copy furnished:

Atty. Mariano Marcos

Private Prosecutor
Unit 103, PARC Bldg., Bru-Ger Subd.,
Pututan, Muntinlupa City