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    Entry of Appearance With Motion For Extension

    Uploaded by

    Manny Sandicho
    The document is a motion filed by the legal counsel of respondent Bryan Dominic Almarvez requesting a 30-day extension to file their counter-affidavit. The counsel was just engaged the day before the counter-affidavit was due, and given the counsel's heavy workload and time constraints, they need additional time to properly prepare and file the counter-affidavit on behalf of their client. Therefore, the counsel is asking the court to grant a 30-day extension until April 2, 2020 to submit the respondent's counter-affidavit.

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    Entry of Appearance With Motion For Extension

    Uploaded by

    Manny Sandicho
    459 views2 pages
    The document is a motion filed by the legal counsel of respondent Bryan Dominic Almarvez requesting a 30-day extension to file their counter-affidavit. The counsel was just engaged the day before the counter-affidavit was due, and given the counsel's heavy workload and time constraints, they need additional time to properly prepare and file the counter-affidavit on behalf of their client. Therefore, the counsel is asking the court to grant a 30-day extension until April 2, 2020 to submit the respondent's counter-affidavit.

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    Entry of Appearance with Motion For Extension

    Original Title

    Entry of Appearance with Motion For Extension

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    The document is a motion filed by the legal counsel of respondent Bryan Dominic Almarvez requesting a 30-day extension to file their counter-affidavit. The counsel was just engaged the day before the counter-affidavit was due, and given the counsel's heavy workload and time constraints, they need additional time to properly prepare and file the counter-affidavit on behalf of their client. Therefore, the counsel is asking the court to grant a 30-day extension until April 2, 2020 to submit the respondent's counter-affidavit.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    459 views2 pages

    Entry of Appearance With Motion For Extension

    Uploaded by

    Manny Sandicho
    The document is a motion filed by the legal counsel of respondent Bryan Dominic Almarvez requesting a 30-day extension to file their counter-affidavit. The counsel was just engaged the day before the counter-affidavit was due, and given the counsel's heavy workload and time constraints, they need additional time to properly prepare and file the counter-affidavit on behalf of their client. Therefore, the counsel is asking the court to grant a 30-day extension until April 2, 2020 to submit the respondent's counter-affidavit.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
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    of 2

    REPUBLIC OF THE PHILIPPINES

    DEPARTMENT OF JUSTICE
    OFFICE OF THE CITY PROSECUTOR
    QUEZON CITY

    MARK ANGELO URI y AGENA, ET. AL.,


    Complainants,
    XV-03-INV-191-11090
    - versus - ESTAFA

    BRYAN DOMINIC ALMARVEZ,


    Respondents.
    x -------------------------------------------------- x

    ENTRY OF APPEARANCE AND


    URGENT MOTION FOR EXTENSION OF TIME
    TO FILE RESPONDENT’S COUNTER-AFFIDAVIT
    RESPONDENT, by undersigned counsel, respectfully states that:

    1. Respondent has been directed to file a Counter-Affidavit by 03 March


    2020.

    2. Undersigned counsel has just been met and engaged today (02 March
    2020) by respondent who had a hard time getting a lawyer that will
    fully assist and work on his case.

    3. Due to time constraints and heavy work-load, undersigned counsel


    cannot possibly prepare and file the counter-affidavit of respondent on
    the next day (03 March 2020) after his assignation as respondent’s
    counsel, because of the tremendous pressure of other equally urgent
    professional work requiring the preparation of pleadings and almost
    daily trial appearances before the various courts.

    4. For this reason, undersigned counsel is constrained to ask for an


    additional thirty (30) days from 03 March 2020 within which to submit
    respondent’s counter-affidavit.

    5. This motion is not intended for delay but is motivated only by the
    foregoing reason.

    WHEREFORE, respondent respectfully prays that respondent be


    granted an additional thirty (30) days from 03 March 2020 or until 02 April
    2020, within which to submit respondent’s counter-affidavit.

    Other reliefs just and equitable are likewise respectfully prayed for.

    RESPECTFULLY SUBMITTED.
    Calamba City for Quezon City; this 02 March 2020.

    Atty. EMMANUEL E. SANDICHO


    Legal Counsel for the Respondent
    nd
    2 Floor HK Building, National Highway, Brgy. Halang
    Calamba City 4027 Laguna, CALABARZON Philippines
    PAGE 2 OF 2

    E-mail: attysandicho@gmail.com / Tel. +6349-3068578


    IBP O.R. No. 105021. 06 January 2020, Laguna Chapter
    PTR O.R. No. 7403275, 06 January 2020, Calamba City
    Roll No. 42246 admitted to practice law, 09 May 1997
    MCLE Compliance Cert. No. VI-0023440, 11 April 2019
    Copy furnished:

    MARK ANGELO A. URI


    ALDWIN R. PICARDAL
    DONNIE CARLO Y. CARLOS
    No. 30-F Liberty Avenue
    Brgy. Socorro, Cubao
    Quezon City NCR

    MARC KENNETH M. MANAHAN


    No. 77 Road 1 West Crame
    San Juan City NCR

    CLARK P. TAGUBA
    No. 491-G Boni Serrano Ave.,
    Brgy. San Roque, Murphy
    Quezon City NCR
    PAGE 2 OF 2

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