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    Regional Trial Court

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    attymel
    The motion requests a 10-day extension of time, until December 1, 2019, to file a reply memorandum in response to the defendant's memorandum. It explains that the plaintiff's counsel had prepared the reply memorandum on time but her laptop crashed and she lost the draft document. While attempting to recover the draft, the technician advised that the laptop was beyond recovery. Counsel has since started drafting the reply again but due to work pressures and other commitments, needs additional time to complete it. The motion asks the court to grant the 10-day extension until December 1st to submit the reply memorandum.

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    Regional Trial Court

    Uploaded by

    attymel
    25 views3 pages
    The motion requests a 10-day extension of time, until December 1, 2019, to file a reply memorandum in response to the defendant's memorandum. It explains that the plaintiff's counsel had prepared the reply memorandum on time but her laptop crashed and she lost the draft document. While attempting to recover the draft, the technician advised that the laptop was beyond recovery. Counsel has since started drafting the reply again but due to work pressures and other commitments, needs additional time to complete it. The motion asks the court to grant the 10-day extension until December 1st to submit the reply memorandum.

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    The motion requests a 10-day extension of time, until December 1, 2019, to file a reply memorandum in response to the defendant's memorandum. It explains that the plaintiff's counsel had prepared the reply memorandum on time but her laptop crashed and she lost the draft document. While attempting to recover the draft, the technician advised that the laptop was beyond recovery. Counsel has since started drafting the reply again but due to work pressures and other commitments, needs additional time to complete it. The motion asks the court to grant the 10-day extension until December 1st to submit the reply memorandum.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    25 views3 pages

    Regional Trial Court

    Uploaded by

    attymel
    The motion requests a 10-day extension of time, until December 1, 2019, to file a reply memorandum in response to the defendant's memorandum. It explains that the plaintiff's counsel had prepared the reply memorandum on time but her laptop crashed and she lost the draft document. While attempting to recover the draft, the technician advised that the laptop was beyond recovery. Counsel has since started drafting the reply again but due to work pressures and other commitments, needs additional time to complete it. The motion asks the court to grant the 10-day extension until December 1st to submit the reply memorandum.

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    REPUBLIC OF THE PHILIPPINES

    NATIONAL CAPITAL JUDICIAL REGION


    REGIONAL TRIAL COURT
    City of Parañaque
    Branch 195

    EVELYN CATBAGAN,                       
             Plaintiff,
                                                            CIVIL CASE No. 2019-262
    -versus- FOR: Unlawful Detainer

    JOSE BARTOLAY.
                          Defendant.
    x---------------------------------------------------x

    MOTION FOR EXTENSION OF TIME


    TO FILE REPLY MEMORANDUM

    1. That on November 7, 2019, plaintiff-appelle received the


    Memorandum for the Defendant-Appellant.

    2. That pursuant to Order of this Honorable Court, plaintiff-appelle has


    fifteen (15) days from the receipt of the said Memorandum or until
    November 22, 2019 within which to file his Reply Memorandum.

    3. That plaintiff-appelle most respectfully begs the indulgence of this


    Honorable Court and moves that he be given additional 10 days or
    until December 1, 2019 within which to file his Reply Memorandum
    on the following grounds:

    a. That the undersigned counsel for the plaintiff-appelle had


    already prepared and finalized her Reply Memorandum on
    time to submit it before this Honorable Court;
    b. That unfortunately, however, the undersigned counsel’s
    laptop just shut down when she was about to save the final
    draft of the said reply.

    c. That the undersigned counsel tried to recover the said


    pleading by fixing the laptop but she was advised by the
    technician that it was already beyond recovery.

    d. That she started to draft again but due to volume and


    pressures of works coupled with other equally important and
    urgent professional commitments, the undersigned counsel
    cannot complete the said Reply Memorandum within the
    period required and will need an additional ten (10) days
    from November 22, 2019 or until December 1, 2019 within
    which to do so.

    e. This motion is being filed due to above reasons stated above


    and not for the purpose of delaying the instant case.

    PRAYER
    WHEREFORE, plaintiff-appellee prays that he be granted an
    additional ten (10) days from November 22, 2019 or until December 1,
    2019 within which to submit a Reply Memorandum.

    Paranaque City, November 20, 2019.

    COS GUEVARRA
    & ASSOCIATES LAW OFFICES
    Counsel for the Defendants-Appellees
    Unit 210 Doña Eusebia Rodriguez Bldg.,
    0611 Quirino Ave., san Dionisio, Parañaque City
    Tel. No.825-99-18

    By:

    ATTY. MELANIE O. GUEVARRA
    Counsel for Defendants-Appellees
    IBP No. 070285; 01-25-19; Pasig City
    PTR No. 1741150; 01-17-19; Parañaque City
    Roll No. 56511
    MCLE Compliance No. VI-0014042

                                                            
    NOTICE OF HEARING

    TABAQUERO ALBANO LOPEZ & ASSOCIATES


    Atty. Ronald E. Javier
    3rd Floor, Unit K, # 854 Sta. Catalina Street,
    San Antonio Avenue Valley 1, Paranaque City 1700

    CLERK OF COURT
    Regional Trial Court
    Branch 195, Paranaque City

              Greetings!
          
    Kindly submit the foregoing motion for consideration and approval of
    this Honorable Court immediately upon receipt hereof.
    EXPLANATION

    Copies of the foregoing Motion for Extension of Time were served to


    the Honorable Court and defendant’s counsel through registered mail
    considering the distance between the address of defendants’ counsel and
    the undersigned counsel. Moreover, the office of the undersigned has no
    personnel to effect personal service to the defendant.

                            
    ATTY. MELANIE OBRIQUE- GUEVARRA

                                               
    Copy furnished:

    TABAQUERO ALBANO LOPEZ & ASSOCIATES


    Atty. Ronald E. Javier
    3rd Floor, Unit K, # 854 Sta. Catalina Street,
    San Antonio Avenue Valley 1, Paranaque City 1700

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