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Entry of Appearance With Motion For Extension

The document is a motion filed by the legal counsel of respondent Bryan Dominic Almarvez requesting a 30-day extension to file their counter-affidavit. The counsel was just engaged the day before the counter-affidavit was due, and given the counsel's heavy workload and time constraints, they need additional time to properly prepare and file the counter-affidavit on behalf of their client. Therefore, the counsel is asking the court to grant a 30-day extension until April 2, 2020 to submit the respondent's counter-affidavit.

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Manny Sandicho
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808 views2 pages

Entry of Appearance With Motion For Extension

The document is a motion filed by the legal counsel of respondent Bryan Dominic Almarvez requesting a 30-day extension to file their counter-affidavit. The counsel was just engaged the day before the counter-affidavit was due, and given the counsel's heavy workload and time constraints, they need additional time to properly prepare and file the counter-affidavit on behalf of their client. Therefore, the counsel is asking the court to grant a 30-day extension until April 2, 2020 to submit the respondent's counter-affidavit.

Uploaded by

Manny Sandicho
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOC, PDF, TXT or read online on Scribd
You are on page 1/ 2

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
QUEZON CITY

MARK ANGELO URI y AGENA, ET. AL.,


Complainants,
XV-03-INV-191-11090
- versus - ESTAFA

BRYAN DOMINIC ALMARVEZ,


Respondents.
x -------------------------------------------------- x

ENTRY OF APPEARANCE AND


URGENT MOTION FOR EXTENSION OF TIME
TO FILE RESPONDENT’S COUNTER-AFFIDAVIT
RESPONDENT, by undersigned counsel, respectfully states that:

1. Respondent has been directed to file a Counter-Affidavit by 03 March


2020.

2. Undersigned counsel has just been met and engaged today (02 March
2020) by respondent who had a hard time getting a lawyer that will
fully assist and work on his case.

3. Due to time constraints and heavy work-load, undersigned counsel


cannot possibly prepare and file the counter-affidavit of respondent on
the next day (03 March 2020) after his assignation as respondent’s
counsel, because of the tremendous pressure of other equally urgent
professional work requiring the preparation of pleadings and almost
daily trial appearances before the various courts.

4. For this reason, undersigned counsel is constrained to ask for an


additional thirty (30) days from 03 March 2020 within which to submit
respondent’s counter-affidavit.

5. This motion is not intended for delay but is motivated only by the
foregoing reason.

WHEREFORE, respondent respectfully prays that respondent be


granted an additional thirty (30) days from 03 March 2020 or until 02 April
2020, within which to submit respondent’s counter-affidavit.

Other reliefs just and equitable are likewise respectfully prayed for.

RESPECTFULLY SUBMITTED.
Calamba City for Quezon City; this 02 March 2020.

Atty. EMMANUEL E. SANDICHO


Legal Counsel for the Respondent
nd
2 Floor HK Building, National Highway, Brgy. Halang
Calamba City 4027 Laguna, CALABARZON Philippines
PAGE 2 OF 2

E-mail: attysandicho@gmail.com / Tel. +6349-3068578


IBP O.R. No. 105021. 06 January 2020, Laguna Chapter
PTR O.R. No. 7403275, 06 January 2020, Calamba City
Roll No. 42246 admitted to practice law, 09 May 1997
MCLE Compliance Cert. No. VI-0023440, 11 April 2019
Copy furnished:

MARK ANGELO A. URI


ALDWIN R. PICARDAL
DONNIE CARLO Y. CARLOS
No. 30-F Liberty Avenue
Brgy. Socorro, Cubao
Quezon City NCR

MARC KENNETH M. MANAHAN


No. 77 Road 1 West Crame
San Juan City NCR

CLARK P. TAGUBA
No. 491-G Boni Serrano Ave.,
Brgy. San Roque, Murphy
Quezon City NCR
PAGE 2 OF 2

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