Scribd
Upload
136 views3 pages

Regional Trial Court

The motion requests a 10-day extension of time, until December 1, 2019, to file a reply memorandum in response to the defendant's memorandum. It explains that the plaintiff's counsel had prepared the reply memorandum on time but her laptop crashed and she lost the draft document. While attempting to recover the draft, the technician advised that the laptop was beyond recovery. Counsel has since started drafting the reply again but due to work pressures and other commitments, needs additional time to complete it. The motion asks the court to grant the 10-day extension until December 1st to submit the reply memorandum.

Uploaded by

attymel
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
136 views3 pages

Regional Trial Court

The motion requests a 10-day extension of time, until December 1, 2019, to file a reply memorandum in response to the defendant's memorandum. It explains that the plaintiff's counsel had prepared the reply memorandum on time but her laptop crashed and she lost the draft document. While attempting to recover the draft, the technician advised that the laptop was beyond recovery. Counsel has since started drafting the reply again but due to work pressures and other commitments, needs additional time to complete it. The motion asks the court to grant the 10-day extension until December 1st to submit the reply memorandum.

Uploaded by

attymel
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd

REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION


REGIONAL TRIAL COURT
City of Parañaque
Branch 195

EVELYN CATBAGAN,                       
         Plaintiff,
                                                        CIVIL CASE No. 2019-262
-versus- FOR: Unlawful Detainer

JOSE BARTOLAY.
                      Defendant.
x---------------------------------------------------x

MOTION FOR EXTENSION OF TIME


TO FILE REPLY MEMORANDUM

1. That on November 7, 2019, plaintiff-appelle received the


Memorandum for the Defendant-Appellant.

2. That pursuant to Order of this Honorable Court, plaintiff-appelle has


fifteen (15) days from the receipt of the said Memorandum or until
November 22, 2019 within which to file his Reply Memorandum.

3. That plaintiff-appelle most respectfully begs the indulgence of this


Honorable Court and moves that he be given additional 10 days or
until December 1, 2019 within which to file his Reply Memorandum
on the following grounds:

a. That the undersigned counsel for the plaintiff-appelle had


already prepared and finalized her Reply Memorandum on
time to submit it before this Honorable Court;
b. That unfortunately, however, the undersigned counsel’s
laptop just shut down when she was about to save the final
draft of the said reply.

c. That the undersigned counsel tried to recover the said


pleading by fixing the laptop but she was advised by the
technician that it was already beyond recovery.

d. That she started to draft again but due to volume and


pressures of works coupled with other equally important and
urgent professional commitments, the undersigned counsel
cannot complete the said Reply Memorandum within the
period required and will need an additional ten (10) days
from November 22, 2019 or until December 1, 2019 within
which to do so.

e. This motion is being filed due to above reasons stated above


and not for the purpose of delaying the instant case.

PRAYER
WHEREFORE, plaintiff-appellee prays that he be granted an
additional ten (10) days from November 22, 2019 or until December 1,
2019 within which to submit a Reply Memorandum.

Paranaque City, November 20, 2019.

COS GUEVARRA
& ASSOCIATES LAW OFFICES
Counsel for the Defendants-Appellees
Unit 210 Doña Eusebia Rodriguez Bldg.,
0611 Quirino Ave., san Dionisio, Parañaque City
Tel. No.825-99-18

By:

ATTY. MELANIE O. GUEVARRA
Counsel for Defendants-Appellees
IBP No. 070285; 01-25-19; Pasig City
PTR No. 1741150; 01-17-19; Parañaque City
Roll No. 56511
MCLE Compliance No. VI-0014042

                                                        
NOTICE OF HEARING

TABAQUERO ALBANO LOPEZ & ASSOCIATES


Atty. Ronald E. Javier
3rd Floor, Unit K, # 854 Sta. Catalina Street,
San Antonio Avenue Valley 1, Paranaque City 1700

CLERK OF COURT
Regional Trial Court
Branch 195, Paranaque City

          Greetings!
      
Kindly submit the foregoing motion for consideration and approval of
this Honorable Court immediately upon receipt hereof.
EXPLANATION

Copies of the foregoing Motion for Extension of Time were served to


the Honorable Court and defendant’s counsel through registered mail
considering the distance between the address of defendants’ counsel and
the undersigned counsel. Moreover, the office of the undersigned has no
personnel to effect personal service to the defendant.

                        
ATTY. MELANIE OBRIQUE- GUEVARRA

                                           
Copy furnished:

TABAQUERO ALBANO LOPEZ & ASSOCIATES


Atty. Ronald E. Javier
3rd Floor, Unit K, # 854 Sta. Catalina Street,
San Antonio Avenue Valley 1, Paranaque City 1700

You might also like