REPUBLIC OF THE PHILIPPINES
SUPREME COURT
MANILA
ALLIED BANKING CORPORATION,
Plaintiff-Appellee,
CA-G.R. CV No. 82001
- versus –
INFINITE REALTY,INC. & MARIE H.
BALTAZAR,
Defendants-Appellants.
X----------------------------------------------------------------X
MOTION FOR EXTENSION OF TIME TO
FILE DEFENDANT-APPELLANT’S BRIEF
COMES NOW, the undersigned counsel for defendant-
appellant in the above-entitled case, and unto this Honorable
Court, hereby respectfully request that he be granted an
extension of time within which to file the defendant –appellant’s
brief.
That on Wednesday, April 6, 2011, the undersigned counsel
received the NOTICE OF RESOLUTION together with the resolution
of the former Twelfth Division” of the Court of Appeals
promulgated on March 11, 2011, denying the undersigned
counsel’s motion for reconsideration.
That the undersigned counsel has fifteen days from receipt
of the said NOTICE OF RESOLUTION on April 6, 2011, within which
to file his brief on Appeal by Certiorari before this Honorable
Court.
That the draft of the defendant-appellant’s brief had already
been started but due to the fact that about four (4) days of the
original fifteen (15) days period had been wasted because of the
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infirmity of the undersigned counsel, coupled by the heavy
pressure of work in the office regarding matters which need
special attention as in the present appeal to this Honorable Court,
including Court Appearances in far away places, the undersigned
counsel cannot possibly meet the deadline for the submission of
defendant-appellant’s brief on April 20, 2011.
That in view thereof, the undersigned counsel has to ask this
HONORABLE COURT for an extension of thirty (30) days from April
21, 2011 the expiration of the original period of fifteen (15) days,
within which to file to defendant-appellant’s brief.
That this motion is not intended to delay the proceeds on
appeal before this Honorable Court but is purely for reasons
heretofore stated.
WHEREFORE, the undersigned counsel hereby respectfully
request’s that he be granted an extension of thirty (30) days
counted from April 21, 2011, or up to May 21, 2011, within which
to file the defendant-appellant’s brief.
Manila, Philippines, April 19, 2011.
ATTY MAMERTO D. PICCIO
Counsel for the Defendant-Appellant
Villanueva and Associates Law Office
Rm.301,3rd/F E. V. Villanueva Jr., Bldg.
1807 L. Guinto St. cor. J. Nakpil St.,
Malate, Manila
IBP No. 486159- Dec. 01, 2009 Pasig
PTR No.A-2065761–Dec. 18, 2009 Q.C.
Roll No. 14130
MCLE Comp. No. I – 0018303 Apr. 13, 2010
MCLE Comp. No. II - 0019162 Apr. 13, 2010
Copy Furnished:
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Ocampo, Guevarra, Llamas and Associates
Counsel for Plaintiff-Appellee
2nd Floor, Allied Bank Center
6754 Ayala, Avenue, Makati City
ALLIED BANKING CORPORATION
2/f, Legal and Collection Department
Allied Bank Center, 6754 Ayala Ave., Makati City
Atty. Donna Lara B. Oropesa
Division Clerk of Court
Former Twelfth Division
Court of Appeals
Maria Orosa Street, Ermita, Manila
NOTICE OF HEARING
The Clerk of Court
Supreme Court
Taft Avenue, Manila
GREETINGS:
Considering the non-litigious nature of this motion, the
undersigned counsel will submit the foregoing motion for the
consideration and approval of this Honorable Court upon its
receipt thereof.
ATTY. MAMERTO D. PICCIO
EXPLANATION
(Pursuant to Sec. 11 of Rule 13, of the Rules of Court)
Copies of this Motion are being served by Registered Mail to
the above-mentioned addresses as personal service thereof is not
practical due to the distance of the said places from the
undersigned’s, residence and lack of personnel to effect personal
delivery of copies of the said pleading.
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ATTY MAMERTO D.
PICCIO
/mdp/jrl2011
