REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
Manila City

BRANCH XX

PEOPLE OF THE PHILIPPINES,

Plaintiff,

-versus- Crim. Case No. XXX

XXX
Accused.
x-----------------------------------------------------------------------------------------x

MOTION FOR EXTENSION OF TIME

Plaintiff, the PEOPLE OF THE PHILIPPINES, through the

Private Prosecutor, under the direct control and supervision of the
Honorable Public Prosecutor, to the Honorable Court, respectfully
states:

1. On 12 February 2019, undersigned Private Prosecutor

received the Comment/Opposition dated 31 January 2019 of accused
to the former’s Motion for Reconsideration dated 22 January 2019.
Based on the Order dated 25 January 2019, the prosecution is given
a period of five (5) days, or until 17 February 2019 1, within which to
file its Reply thereto.

2. Undersigned Private Prosecutor has already commenced

drafting the Reply. However, undersigned Private Prosecutor
anticipates his inability to finalize and file the same within the original
5-day period due to tremendous pressure of other equally urgent
professional work which requires the preparation of numerous
pleadings and attendance of court hearings and meetings.

3. Under the premises undersigned Private Prosecutor

respectfully begs for the charitable indulgence of the Honorable Court
and prays for an additional period of three (3) days from 17
February 2019, or until 20 February 2019, within which to finalize
and file the aforestated Reply.

1
17 February 2019 falls on a Sunday.
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 4. This Motion for Extension of Time is prompted only by the
foregoing circumstances and is being filed in good faith and without
any intention to delay the earliest possible resolution of the case.

PRAYER

WHEREFORE, premises considered, plaintiff respectfully prays

that the Honorable Court GRANT it an additional period of three (3)
days from 17 February 2019, or until 20 February 2019, within
which to file its Reply.

Other just and equitable reliefs are likewise prayed for.

Respectfully submitted.

City of Makati for the City of Manila.

18 February 2019.

XXXXXXX
Law Offices
Private Prosecutor

By:

XXX
Roll No. xxx

Conforme:

XXXX
Public Prosecutor
Regional Trial Court
Branch xx
Manila City

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 REQUEST FOR HEARING

THE BRANCH CLERK OF COURT

Regional Trial Court of Manila
Branch XX

Greetings:

Due to the nature of the foregoing Motion, kindly submit the

same to the Honorable Court for its consideration and approval
immediately upon receipt hereof.

XXX

NOTICE AND COPY FURNISHED

XXX

Greetings:

Please take notice that undersigned counsel has requested the

Honorable Court’s Branch Clerk of Court to submit the foregoing
Motion immediately upon receipt hereof to the Honorable Court for its
consideration and approval.

XXX

EXPLANATION
(Re: Service through Registered Mail)

Unless otherwise personally served, a copy of this pleading

was served upon the foregoing addressees by means of registered
mail with return card in accordance with Sections 5, 7, 11 and 13 of
Rule 13 of the 1997 Rules of Civil Procedure and/or private courier,
on account of the distance between the undersigned counsel’s office
and that of the said addressees, as well as the lack of material time
and messengerial personnel to effect personal service.

XXX

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