REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT
FIRST JUDICIAL REGION
BAGUIO CITY BRANCH 3

PEOPLE OF THE PHILIPPINES,
Plaintiff,
Criminal Case No.
vs. For Estafa

LEO CABAEL and ALMA CABAEL
Accused.
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MOTION TO FOR ADDITIONAL TIME
TO FILE MEMORANDUM
THE PEOPLE OF THE PHILIPPINES, by the undersigned counsel
under the supervision and control of the Honorable Public Prosecutor, most
respectfully prays for additional five (5) days to file its memorandum to
allow it time to submit to the public prosecutor for signature considering that
the undersigned counsel is out of town. Attached is a copy of the draft
memorandum as Annex “A”.

This motion is submitted based on the foregoing grounds and is not
intended to delay the ex parte hearing of the instant criminal case.

RESPECTFULLY SUBMITTED.

Baguio City, March 14, 2017.

ATTY.
Baguio City
IBP No. , January 20, 2012, Cebu
PTR. No. , October 9, 2010, Baguio City
MCLE Compliance No.
IBP Roll No.
Mobile No.
Email:

Conforme:

ASST. CITY PROSECUTOR

: _________________________ Issued at : _________________________ Date : _________________________ EXPLANATION (In accordance with Section 11 Rule 13 of the 1997 Rules of Civil Procedure) The foregoing Motion is being served on the other party(ies) through courier/registered mail due to the lack of material time. Copy served by registered mail: ATTY. . ATTY. all of which factors make personal service impracticable. the distance involved and the lack of adequate messengerial personnel. NOTICE OF HEARING The Clerk of Court Regional Trial Court Branch 3 Baguio City Greetings: Kindly submit the foregoing motion for the consideration and approval of the Honorable Court immediately upon your receipt hereof. This mode of service is adopted in good faith and is not intended to unduly or improperly delay the proceedings in the instant case but solely for the aforementioned considerations. Counsel of Accused Ermita Manila Philippines LBC Receipt No. ATTY.