Republic of the Philippines

DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES

Community Environment and Natural Resources Office
Talibon, Bohol

CYNTHIA P. DE LA CRUZ, as represented by ARLENE P. SENO

Claimant-Protestant

CENRO Case No. 2020-07

Situated in the
Barrio of : Poblacion`
Mun. of : Ubay
Province of : Bohol

-versus-

JOVITA S. CANO,
Applicant- Respondent
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MOTION FOR EXTENSION OF TIME TO FILE POSISTION

PAPER

Petitioners, thru undersigned counsel, unto this Most Honorable

Tribunal most respectfully state:

1. That on August 2, 2021, the parties agreed to do away with the pre-trial
proceeding and proceed immediately with the submission of their
respective position papers;

2. That on the same date, the parties agreed to submit their respective
position papers within 60 days from said date or October 2, 2021 but
since October 2, 2021 is a non-working day, the deadline shall be the
next working day, October 4, 2021.

3. That unfortunately the claimant-protestant, Cynthia P. De La Cruz died

on September 11, 2021;

4. That by reason of said death, the appointed substitute for the claimant-
protestant, Arlene P. Seno, has a hard time locating all of the documents
pertinent to the position of the claimant-protestant;

5. That this motion is not made to delay the process but only to comply
genuinely with mandatory orders concerning the position paper.
 PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of

this Honorable Tribunal that the undersigned counsel be granted additional
time up to October 19, 2021 within which to file the Position Paper.

Other reliefs just and equitable are prayed for.

Municipality of Ubay, October 4, 2021

RESPECTFULLY SUBMITTED.

ATTY. MICHAEL JORDAN M. TUBAL

NOTARY PUBLIC
ALBURQUERQUE, BOHOL, PHILIPPINES
NC NO. 2020-11-157 VALID UNTIL DEC. 31, 2021
ROLL NO. 75791 IBP NO. 129713
MCLE EXEMPT (NEW LAWYER)
TIN NO. 773-097-726-000 PTR NO. 0620479 FOR CY 2021

Copy furnished:
ATTY. DELANAROSE A. DEL ROSARIO
Tagbilaran City, Province of Bohol