REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

FIRST JUDICIAL REGION
BAGUIO CITY BRANCH 3

PEOPLE OF THE PHILIPPINES,

Plaintiff,
Criminal Case No.
vs. For Estafa

LEO CABAEL and ALMA CABAEL

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

MOTION TO FOR ADDITIONAL TIME

TO FILE MEMORANDUM
THE PEOPLE OF THE PHILIPPINES, by the undersigned counsel
under the supervision and control of the Honorable Public Prosecutor, most
respectfully prays for additional five (5) days to file its memorandum to
allow it time to submit to the public prosecutor for signature considering that
the undersigned counsel is out of town. Attached is a copy of the draft
memorandum as Annex A.

This motion is submitted based on the foregoing grounds and is not

intended to delay the ex parte hearing of the instant criminal case.

RESPECTFULLY SUBMITTED.

Baguio City, March 14, 2017.

ATTY.
Baguio City
IBP No. , January 20, 2012, Cebu
PTR. No. , October 9, 2010, Baguio City
MCLE Compliance No.
IBP Roll No.
Mobile No.
Email:

Conforme:

ASST. CITY PROSECUTOR

 NOTICE OF HEARING

The Clerk of Court

Regional Trial Court Branch 3
Baguio City

Greetings:

Kindly submit the foregoing motion for the consideration and approval
of the Honorable Court immediately upon your receipt hereof.

ATTY.

Copy served by registered mail:

ATTY.
Counsel of Accused
Ermita Manila
Philippines

LBC Receipt No. : _________________________

Issued at : _________________________
Date : _________________________

EXPLANATION
(In accordance with Section 11 Rule 13
of the 1997 Rules of Civil Procedure)

The foregoing Motion is being served on the other party(ies) through

courier/registered mail due to the lack of material time, the distance
involved and the lack of adequate messengerial personnel, all of which
factors make personal service impracticable.

This mode of service is adopted in good faith and is not intended to

unduly or improperly delay the proceedings in the instant case but solely for
the aforementioned considerations.

ATTY.