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Court of Appeals: Manila

The petitioners filed a motion for extension of time to file a reply to the private respondent's comment on their petition for certiorari. They request an additional 15 days, until September 21st, to submit their reply due to the volume of documents attached by the private respondent and the counsel's heavy workload. They assure the court that the request is not to delay proceedings but due to the stated reasons. The petitioners pray that their request for an extension be granted.

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194 views3 pages

Court of Appeals: Manila

The petitioners filed a motion for extension of time to file a reply to the private respondent's comment on their petition for certiorari. They request an additional 15 days, until September 21st, to submit their reply due to the volume of documents attached by the private respondent and the counsel's heavy workload. They assure the court that the request is not to delay proceedings but due to the stated reasons. The petitioners pray that their request for an extension be granted.

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colenearcaina
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Republic of the Philippines

COURT OF APPEALS
Manila

JUAN DELA CRUZ & ANNIE


BATUNGBACAL
Petitioners,
CA-G.R. SP. No. 123456
- versus -

HON. JUDGE HUSGADO &


PEDRO CORPORATION,
Respondents.
x ----------------------------------------- x

MOTION FOR EXTENSION OF TIME TO FILE REPLY


with
COMPLIANCE

Petitioners, through counsel, and unto this Honorable Court,


most respectfully state:

1. On 1 September 2018, Petitioners, through counsel,


received the Comment to the Petition for Certiorari of Private
Respondent Guerrero Estate Development Corp.

2. In accordance with the Resolution of the Honorable Court,


the Petitioners have five (5) days upon receipt of Private
Respondent’s Comment within which to submit their Reply.

3. They have until 6 September 2018 to do so.

4. However, considering the voluminous documents


attached by the Private Respondent in their Comment, the
undersigned counsel needs additional time to thoroughly evaluate
the documents presented therein.

5. At the same time, he has to cope with tremendous


pressure of other equally urgent professional work requiring almost
daily trial appearances before the various courts within and outside
Metro Manila, preparation of pleadings and other time-intensive
activities,

6. Hence, in the interest of justice, Petitioners are


constrained to respectfully request from the Honorable Court an

1
additional period of fifteen (15) days, reckoned from 6 September
2018, or until 21 September 2018, within which to submit their Reply.

7. Rest assured, this motion is not being filed to delay the


proceeding, but only due to the reasons cited above.

PRAYER

WHEREFORE, Petitioners respectfully pray from the


Honorable Court that the request for an additional period of fifteen
(15) days, reckoned from 6 September 2018, or until 21 September
2018, within which to submit their Reply be GRANTED and their
manifestation by way of Compliance be NOTED by this Honorable
Court.

Other just and equitable reliefs under the premises are likewise
prayed for.

Respectfully submitted.

Makati City for Manila City, 4 September 2018.

ABC LAW OFFICES


Counsel for the Petitioners
Unit 555, Ligo Building
Sardinas Street
1230 Makati City
Email: mail@abclaw.com
Tel. Nos. 887-0000

By:

ABOGADO ABOGADO
Roll No. 222222
PTR No. 987654 /Jan. 9, 2020 / Makati City
IBP No. 78900/ Jan. 11, 2020 / Makati City
MCLE Compliance No. VI-000000|July 4, 2018

EXPLANATION

This pleading is served upon the Respondents and filed before


the Honorable Court by registered mail in accordance with Section
11, Rule 13 of the Rules of Court due to time constraints and
inadequacy of messengerial services.

2
ABOGADO ABOGADO

COPY FURNISHED:

THE HONORABLE PRESIDING JUDGE


Regional Trial Court, Branch 111, Quezon City
7th Floor, Hall of Justice, Makati City

LAWYER LAWYER
Counsel for Respondents
Unit 54 Canton Tower
1216 6th Avenue,
Quezon City

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