Republic of the Philippines

REGIONAL TRIAL COURT

11th Judicial Region
Branch 33
Davao City
THE PEOPLE
PHILIPPINES,

OF

THE

CRIM. CASE NO. xxxxxx

FOR:

-versusJuan Dela Cruz,

Accused.
x- - - - - - - - - - - - - - - - - - - - - -x

ESTAFA

MOTION FOR EXTENSION OF TIME

TO FILE MEMORANDUM
Accused, by the undersigned counsel, and unto this
Honorable Court, most respectfully states that:
1. On April 11, 2016, the Honorable Court issued an
Order directing the parties to file within fifteen (15)
days their respective memoranda;
2.

However, due to the pressures of equally urgent

professional work and prior commitments, the
undersigned counsel will not be able to meet the said
deadline;

3.

As such, undersigned counsel is constrained to request

for an additional period of fifteen (15) days from today,
April 26, 2016, within which to submit Accuseds
memorandum;

4.

This Motion is not intended for delay but solely due to

the foregoing reasons.
PRAYER

WHEREFORE, Accused most respectfully prays that

the Honorable Court to give her an additional period of
fifteen (15) days from today, April 26, 2016, within which to
submit her memorandum.
Other reliefs, just and equitable, are likewise prayed
for.
RESPECTFULLY SUBMITTED this 26th day of April
2016, in the City of Davao, Philippines.
(NAME OF COUNSEL)
Copy furnished:
EXPLANATION
(Please disregard if delivered personally.)
Copies of this Motion for Extension of Time to File
Memorandum were served to the parties and filed in court

through registered mail due to distance, time constraints,

and lack of personnel to effect personal service.

(NAME OF COUNSEL)

NOTICE OF HEARING
The Clerk of Court
RTC Branch 33, Davao City
(Parties)
Please be informed that the foregoing motion is set for
the consideration of the Honorable Court on April 29, 2016,
or on any date and time preferred by the Honorable Court,
sans appearance of counsel.

(NAME OF COUNSEL)

Pros. Robert Michael N. Razon

Pros. Karl Andre G. Salcedo
RSPO, Ecoland, Davao City
REGIONAL TRIAL COURT
Branch 33
Ecoland, Davao City