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    Practice Court

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    Gia Santiago
    The motion requests a 15-day extension to file a memoranda, from the original deadline of March 2, 2019 to a new deadline of March 17, 2019. It states that the case was recently assigned to the filing attorney and more time is needed to adequately prepare the memoranda. The motion is not intended to delay the case but is needed due to the reasons stated. The motion asks the court to approve the 15-day extension for filing the memoranda.

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    Practice Court

    Uploaded by

    Gia Santiago
    45 views2 pages
    The motion requests a 15-day extension to file a memoranda, from the original deadline of March 2, 2019 to a new deadline of March 17, 2019. It states that the case was recently assigned to the filing attorney and more time is needed to adequately prepare the memoranda. The motion is not intended to delay the case but is needed due to the reasons stated. The motion asks the court to approve the 15-day extension for filing the memoranda.

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    Comment for practice court

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    The motion requests a 15-day extension to file a memoranda, from the original deadline of March 2, 2019 to a new deadline of March 17, 2019. It states that the case was recently assigned to the filing attorney and more time is needed to adequately prepare the memoranda. The motion is not intended to delay the case but is needed due to the reasons stated. The motion asks the court to approve the 15-day extension for filing the memoranda.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    45 views2 pages

    Practice Court

    Uploaded by

    Gia Santiago
    The motion requests a 15-day extension to file a memoranda, from the original deadline of March 2, 2019 to a new deadline of March 17, 2019. It states that the case was recently assigned to the filing attorney and more time is needed to adequately prepare the memoranda. The motion is not intended to delay the case but is needed due to the reasons stated. The motion asks the court to approve the 15-day extension for filing the memoranda.

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    REPUBLIC OF THE PHILIPPINES

    NATIONAL CAPITAL JUDICIAL REGION


    REGIONAL TRIAL COURT
    BRANCH 69, MANILA

    INTESTATE ESTATE OF GINA LOPEZ,


    Plaintiff,

    -versus- Civil Case No.: G.R. No. 112233

    JENNIFER LOPEZ,
    Respondent.

    x---------------------------------------------------------------------------------------x

    MOTION FOR EXTENSION OF TIME

    Plaintiff, by counsel, respectfully states that:

    1. She has been required to file a Memoranda within 15 days from 15


    February 2019 which was when the Plaintiff received the notice,
    or on or before 2 March 2019;

    2. The undersigned counsel, however, anticipates her inability to file


    the Memoranda on or before the said date because the case has
    only been recently assigned to the undersigned and that we are
    still in the process of preparing said Memoranda. For these
    reasons, the undersigned is constrained to ask for an additional
    15 days from 2 March 2019 within which to submit the Plaintiff’s
    Memoranda.

    3. This motion is not intended to delay but is motivated only by the


    foregoing reasons.

    WHEREFORE, Plaintiff respectfully prays that she be granted additional


    15 days from 2 March 2019, or until 17 March 2019, within which to
    submit Plaintiff’s Memoranda.

    March 1, 2019, Manila.


    Atty. Angelica Ernestine L. Baroña
    Counsel for Plaintiff
    Matatapang at Dalubhasa Law Offices
    89 Mindanao Ave. Quezon City
    Attorney’s Roll No. 12345
    IBP No. 123456; January 1, 2019; Quezon City
    PTR No. 123456; January 1, 2019; Quezon City
    MCLE No. 123456; January 1, 2022

    NOTICE OF HEARING

    Branch Clerk of Court


    RTC – Branch 69
    Manila

    Greetings!

    Due to the non-litigious character of the foregoing, kindly submit


    the foregoing motion for extension of time and approval of this
    Honorable Court immediately upon receipt thereof.

    Atty. Juan dela Cruz

    Explanation of Service: Due to lack of manpower, a copy of this motion


    shall be served by registered mail.

    Copy furnished:

    Atty. John Doe


    Counsel for Defendant
    12 Tower 3, 45 Blvd., Manila

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