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REPUBLIC OF THE PHILIPPINES

COURT OF APPEALS
MANILA

GIRLY GIRON-CHAVEZ,
Petitioner,
C.A. G.R. No. 38438
-versus- (Crim. Case No. 156507)
For: Slight Physical Injuries
PEOPLE OF THE
PHILIPPINES
and ESPERANZA A.
DOMDOM,

Respondents-Appellees.

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MOTION FOR EXTENSION OF TIME TO
MEMORANDUM OF APPEAL

Respondent, ESPERANZA A. DOMDOM, by counsel, unto this
Honorable Court, respectfully states:

1. On 26 January 2017, herein Respondent received a Notice
to Memorandum of Appeal.

2. Per the Honorable Court’s Notice dated 13 January 2017,
appellee has fifteen (15) days from receipt of the Notice to
file Memorandum of Appeal or until 10 February 2017.

3. However, due to the heavy volume of work consisting of
drafting of equally urgent pleadings, court appearances,
client conferences and other similar works, coupled with
the busy schedule involving personal and family
commitments, the undersigned counsel needs more time
to prepare Memorandum for herein appellee.

4. Hence the undersigned counsel is constrained to move for
an additional period of fifteen (15) days from 09 February
2017 or until 24 February 2017 within which to file the
Memorandum.

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LORENZO MARVIN S. premises considered. are likewise prayed for. 12 Rome St. Pasig City FORTUN AND SANTOS LAW OFFICES Counsel for the Petitioner 2 . 09 February 2017. DOMDOM be granted an extension of fifteen (15) days from today. 5. M. Manila BRANCH CLERK OF COURT Regional Trial Court Branch 167 Pasig City OFFICE OF THE CITY PROSECUTOR Hall of Justice Pasig City GIRLY GIRON-CHAVEZ Petitioner No. 2017. within which to file his Appellant’s Brief. 01-27-2017 MCLE (exempted) Admitted to the Bar : 2016 Copy Furnished: COURT OF APPEALS CA Building. Pikador Street.Pasig. Midtown Subdivision San Roque. REYES Counsel for the Respondent 27. or until 24 February 2017. 2692851 . PRAYER WHEREFORE. February 2. Ciudad Grande. This motion is interposed solely for the aforementioned reason and is not intended to delay the proceedings in this case. ESPERANZA A. 1071676. 66539 IBP Roll No. Orosa Street Ermita. it is most respectfully prayed of this Honorable Court that Respondent. Other reliefs. just and equitable. RSM PTR No. Marikina Roll of Attorneys No. Marikina City for Manila City.

BF Homes Almanza Las Pinas City 1750 OFFICE OF THE SOLICITOR GENERAL 134 Amorsolo St.134 CRM Avenue. REYES 3 .. Legaspi Village Makati City EXPLANATION Copies of the foregoing Motion for Extension were filed and served on the above-named parties through registered mail for lack of material time and extreme urgency for the timely filing and service of the same. LORENZO MARVIN S.