REPUBLIC OF THE PHILIPPINES

National Capital Judicial Region 83

Regional Trial Court

Branch 69, Manila

ELPIDIO V. MONTILA AND OR

HEIRS OF ELPIDIO V. MONTILLA,
Plaintiffs’,
Delete CIVIL CASE NO.112233
-versus- apostrophe FOR: SUM OF MONEY

EUGENIO DALAUTA comma

respondent. Respondent. Space comma
x ------------------------------------------ x naman
MOTION FOR EXTENSION OF TIME TO FILE MEMORANDUM
Delete apostrophe
COMES NOW the Plaintiffs’ through Counsel, and unto this
Honorable Court, most respectfully states that:
1. On the 20th of February, 2020, an order was issued by the
Ano ba talaga Regional Trial Court (RTC) of Manila, Branch 69 requiring the herein
tawag sa parties petitioners to file their memoranda in the above case within fifteen
mo? (15) days from receipt thereof. semi-colon
2. The said order was received by MATATAPANG AT DALUBHASA
(MAD) LAW OFFICES, on the 1ST of March, 2020. semi-colon
3. However, on the 10th of March, 2020, the herein counsel was a
Thus, she needs
newly hired lawyer of MAD and this case was the first case assigned
to her. And that she needed more time to study and prepare for the
required Memorandum. semi-colon
4. Furthermore, there was a Memorandum from the Office of
Executive Secretary for Community Quarantine over the entire Metro
Manila pursuant to Proclamation Nos. 929 (s. of 2020) and Republic
Act No. 11332, following the sharp increase in COVID-19 cases.semi-colon
5. For this reason, the undersigned counsel ask this Honorable asks
Court for additional fifteen (15) calendar days from 16TH of
space
March,2020, or until 31st of March, 2020, within which to submit
plaintiffs’ memorandum. ; + and
6. The postponement sought is interposed not for purposes of
delay.
 PRAYER
the plaintiffs
WHEREFORE, all the foregoing considered, it is most respectfully
prayed of this Honorable Court that she be granted the additional
fifteen (15) calendar days from 16th of March, 2020, or until 31st of
March, 2020, within which to submit plaintiffs’ memorandum.

Other reliefs just and equitable are likewise prayed for.

Santiago City, Isabela, for Manila, March 13, 2020.

ELEONOR A. BULATAO
Counsel of the Plaintiffs
Lachica St., Barangay Rizal,
Santiago City, Isabela
Attorney’s Roll No. 56247
IBP No. 0154566/January 04, 2020/Manila
PTR No. 014523/ January 04, 2020/Manila
MCLE Compliance No. 11-00083469
NOTICE OF HEARING
To:
Atty. Enan M. Inton
Counsel of the Respondent
Inton Law Office
Third Floor, Santa Ignacia Bldg.,
Santa Ignacia, Tarlac
Greetings:
Please take notice that as soon thereafter as counsel may be heard,
the undersigned will ask Branch 69 of the Regional Trial Court (RTC)
of Manila to approve the foregoing motion for extension of time to
file memorandum.
 ELEONOR A. BULATAO
Counsel of the Plaintiffs
Lachica St., Barangay Rizal,
Santiago City, Isabela
Attorney’s Roll No. 56247
IBP No. 0154566/January 04, 2020/Manila
PTR No. 014523/ January 04, 2020/Manila
MCLE Compliance No. 11-00083469

COPY FURNISHED TO:

Eugenio Dalauta
The Respondent
Saniata Street, Brgy. Botbotones,
Santa Ignacia, Tarlac
Atty. Enan M. Inton
Counsel of the Respondent
Inton Law Office
Third Floor, Santa Ignacia Bldg.,
Santa Ignacia, Tarlac WHERE?????

PROOF OF SERVICE
EXPLANATION
Pursuant to Section 11, Rule 13 of the Revised Penal Rules of Court,
the Respondent and his Counsel were furnished a copy of the Motion
for extension of time by registered mail with return card due to
distance, lack of office messenger and Community
Quarantine/lockdown of Metro Manila due to Novel Corana
Virus/COVID-19 that makes personal delivery hardly feasible.
COPY FURNISHED TO:
Eugenio Dalauta
The Respondent
Saniata Street, Brgy. Botbotones,
Santa Ignacia, Tarlac
Atty. Enan M. Inton
Counsel of the Respondent
Inton Law Office
Third Floor, Santa Ignacia Bldg.,
Santa Ignacia, Tarlac