REPUBLIC OF THE PHILIPPINES

COURT OF APPEALS
MANILA

PEOPLE OF THE PHILIPPINES,

Plaintiff-Appellee,
- versus - _______________________
_______________________
_______________________
____________________________
____________________________
____________________________

MOTION TO ADMIT REPLY BRIEF

Accused-Appellant ________________ by counsel, respectfully

states:

1. On April 17, 2018, his counsel received the Appellee’s Brief

(“Brief”). The Brief contains several allegations of fact and law that may
mislead this Honorable Court and that need to be corrected. For this
reason, ____________ intends to file a Reply Brief.

2. However, due to the inadvertence of the law intern

assigned to handle the case at that time, the receipt of the Brief was
only discovered on June 5, 2018. The law intern’s inadvertence was
inexcusable.

3. Rule 44, Sec. 9 of the 1997 Rules of Civil Procedure

provides that the Appellant may file within 20 days from the receipt of
the Appellee’s Brief a Reply Brief answering points in the Appellee’s
Brief not covered in the Appellant’s Brief.

4. Under existing rules, a Reply Brief can no longer be filed

as a matter of course. However, in the interests of substantial justice
and equity, _______________, an indigent who is in prison, seeks
leave of this Honorable Court to admit the attached Reply Brief.

RELIEF
 2

WHEREFORE, Accused-Appellant _______________

respectfully prays that this Honorable Court grant him leave to file a
Reply Brief and to admit the attached Reply Brief.

All other just or equitable reliefs are also prayed for.

Quezon City, _______________

By:

ATTY A
Supervising Lawyer
Roll of Attorneys No. ___________
MCLE Compliance No. ___________
IBP No. ___________
PTR No. ___________

COPY FURNISHED
Office of the Solicitor General
Counsel for the Plaintiff-Appellee
134 Amorsolo Street
Legazpi Village, Makati City

JURAT

SUBSCRIBED AND SWORN to before me, this ___________ day of

___________, in the City of ___________, by ___________ with
identification card ___________ issued on ___________.

Notary Public
Doc. No. ___________;
Page No. ___________;
Book No. ___________;
Series of ___________;