Republic of the Philippines

COURT OF APPEALS
Manila

YUNG KAI KWAN

Petitioner,

-versus-

HON. CHIKADORO ET AL.

Respondents.

x-------------------------------------------------x

MOTION FOR EXTENTION

OF TIME TO FILE REPLY
Petitioner, through counsel, unto this Honorable Court, most
respectfully states that:

1. This Honorable Court in its Resolution dated 18 October

2019 has directed the Private Respondents to file its Comment within ten
(10) days from notice and in turn, Petitioner may within five (5) days
from receipt of Private Respondent’s Comment to file its Reply.

2. On 16 January 2020, Petitioner through counsel received a

copy of Private Respondents’ Comment ( On Petition for Certiorari and
Prohibition) dated 8 January 2020.

3. Petitioner has until 21 January 2020 to file its Reply.

However, due to pressures of equally urgent professional work, other
prior commitments and humanitarian activities for the victims of Taal
Volcano’s Phreatic explosion, the undersigned counsel will not be able to
meet the deadline for the filing of its Reply.

4. As such, the undersigned counsel is constrained to request

this Honorable Court for an additional period of ten (10) days from today
within which to submit its Reply to Private Respondents’ Comment.

5. This Motion is not intended for delay but soley due to the
aforementioned reasons.

PRAYER

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 WHEREFORE, Petitioner most respectfully prays of this
Honorable Court that it be given an additional period of Ten (10) days
from today within which to submit its Reply to Private Respondents’
Comment on the instant Petition.

Other relief just and equitable are likewise prayed for.

Quezon City for Manila, 21 January 2020.

ARCISO DY-PO & ASERIT LAW OFFICES

Suite 610, The Tower at Emerald Square, J.P. Rizal
cor. P. Tuazon, Project 4, Quezon City
Tel. Nos.: 2690069; Mobile: 09258187969; 09171339839
Email Address: dypolaw@gmail.com

Dondi K. Dy-Po
IBP Lifetime No. 08666 - January 6, 2010; Rizal IBP Chapter
PTR No. 2847198/01-16-2019; Mandaluyong City
Roll of Attorneys No. 50633
MCLE Compliance No. VI– 0025355/ April 11, 2019

Copy furnished:

HON. NOEL L. PAREL

Regional Adjudicator
Regional Agrarian Reform
Adjudication Board (RARAB),
San Fernando Pampanga (Region III)
DAR Regional Office III,
San Fernando, Pampanga;
(with complete attachments)

NESTOR ESGUERRA, et al.,

Barangays Bundagul, Paraluyunan,
Mabalacat, Pampanga,
and Sto. Rosario, Magalang,
Pampanga
(with complete attachments)

Atty. ANSELMO M. CARLOS

6TH Floor, Strata 2000 Bldg.,
Emerald Avenue, Pasig City
(without attachments)

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 EXPLANATION ON PREFERRED MODE OF SERVICE

It is respectfully manifested that service/filing of the instant motion

was/were made through registered mail due to lack of personnel to effect
personal service/filing and time constraint.

Dondi K. Dy-Po

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