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Motion for Extension of Time to File Appellant

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Jasmin Adarna
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37 views

Motion for Extension of Time to File Appellant

Uploaded by

Jasmin Adarna
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOC, PDF, TXT or read online on Scribd
You are on page 1/ 4

REPUBLIC OF THE PHILIPPINES

SUPREME COURT
MANILA

ALLIED BANKING CORPORATION,


Plaintiff-Appellee,
CA-G.R. CV No. 82001
- versus –

INFINITE REALTY,INC. & MARIE H.


BALTAZAR,
Defendants-Appellants.
X----------------------------------------------------------------X

MOTION FOR EXTENSION OF TIME TO


FILE DEFENDANT-APPELLANT’S BRIEF

COMES NOW, the undersigned counsel for defendant-


appellant in the above-entitled case, and unto this Honorable
Court, hereby respectfully request that he be granted an
extension of time within which to file the defendant –appellant’s
brief.

That on Wednesday, April 6, 2011, the undersigned counsel


received the NOTICE OF RESOLUTION together with the resolution
of the former Twelfth Division” of the Court of Appeals
promulgated on March 11, 2011, denying the undersigned
counsel’s motion for reconsideration.

That the undersigned counsel has fifteen days from receipt


of the said NOTICE OF RESOLUTION on April 6, 2011, within which
to file his brief on Appeal by Certiorari before this Honorable
Court.

That the draft of the defendant-appellant’s brief had already


been started but due to the fact that about four (4) days of the
original fifteen (15) days period had been wasted because of the
2

infirmity of the undersigned counsel, coupled by the heavy


pressure of work in the office regarding matters which need
special attention as in the present appeal to this Honorable Court,
including Court Appearances in far away places, the undersigned
counsel cannot possibly meet the deadline for the submission of
defendant-appellant’s brief on April 20, 2011.

That in view thereof, the undersigned counsel has to ask this


HONORABLE COURT for an extension of thirty (30) days from April
21, 2011 the expiration of the original period of fifteen (15) days,
within which to file to defendant-appellant’s brief.

That this motion is not intended to delay the proceeds on


appeal before this Honorable Court but is purely for reasons
heretofore stated.

WHEREFORE, the undersigned counsel hereby respectfully


request’s that he be granted an extension of thirty (30) days
counted from April 21, 2011, or up to May 21, 2011, within which
to file the defendant-appellant’s brief.

Manila, Philippines, April 19, 2011.

ATTY MAMERTO D. PICCIO


Counsel for the Defendant-Appellant
Villanueva and Associates Law Office
Rm.301,3rd/F E. V. Villanueva Jr., Bldg.
1807 L. Guinto St. cor. J. Nakpil St.,
Malate, Manila
IBP No. 486159- Dec. 01, 2009 Pasig
PTR No.A-2065761–Dec. 18, 2009 Q.C.
Roll No. 14130
MCLE Comp. No. I – 0018303 Apr. 13, 2010
MCLE Comp. No. II - 0019162 Apr. 13, 2010
Copy Furnished:
3

Ocampo, Guevarra, Llamas and Associates


Counsel for Plaintiff-Appellee
2nd Floor, Allied Bank Center
6754 Ayala, Avenue, Makati City

ALLIED BANKING CORPORATION


2/f, Legal and Collection Department
Allied Bank Center, 6754 Ayala Ave., Makati City

Atty. Donna Lara B. Oropesa


Division Clerk of Court
Former Twelfth Division
Court of Appeals
Maria Orosa Street, Ermita, Manila

NOTICE OF HEARING

The Clerk of Court


Supreme Court
Taft Avenue, Manila

GREETINGS:

Considering the non-litigious nature of this motion, the


undersigned counsel will submit the foregoing motion for the
consideration and approval of this Honorable Court upon its
receipt thereof.

ATTY. MAMERTO D. PICCIO

EXPLANATION
(Pursuant to Sec. 11 of Rule 13, of the Rules of Court)

Copies of this Motion are being served by Registered Mail to


the above-mentioned addresses as personal service thereof is not
practical due to the distance of the said places from the
undersigned’s, residence and lack of personnel to effect personal
delivery of copies of the said pleading.
4

ATTY MAMERTO D.
PICCIO

/mdp/jrl2011

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