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Motion for Time Extension in Murder Case

The public attorney representing the accused in a murder case requests a 10-day extension to file a memorandum. They accepted the case late in the trial and need more time to review the voluminous records. Their normal workload also prevents filing within the initial 30-day period granted. They ask the court to extend the deadline to May 15th to allow sufficient time to adequately represent their clients.

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28 views2 pages

Motion for Time Extension in Murder Case

The public attorney representing the accused in a murder case requests a 10-day extension to file a memorandum. They accepted the case late in the trial and need more time to review the voluminous records. Their normal workload also prevents filing within the initial 30-day period granted. They ask the court to extend the deadline to May 15th to allow sufficient time to adequately represent their clients.

Uploaded by

Avocat Coeur
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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REPUBLIC OF THE PHILIPPINES

FOURTH JUDICIAL REGION


REGIONAL TRIAL COURT
BRANCH 83
TANAUAN CITY, BATANGAS

PEOPLE OF THE PHILIPPINES,


Plaintiff,
-versus- Crim. Case No. 07-06-3603
For: Murder
LEONARDO DE LEON y
ENDAYA, ET. AL.,
Accused.
x---------------------------------------------------------------------------x
MOTION FOR EXTENSION OF TIME
TO FILE MEMORANDUM FOR ACCUSED

Accused, by counsel, most respectfully states:

1. Undersigned accepted and entered her appearance as counsel only on 10


April 2017, during the presentation of the prosecution’s presentation of
rebuttal evidence;

2. On even date, presentation of rebuttal evidence concluded and the private


prosecutor rest his case; as there being no sur-rebuttal on the part of
defense, the case now reached the end of trial;

3. Considering the same, the undersigned requested and was granted thirty
(30) days within which to submit memorandum for the defense;

4. However, considering that undersigned counsel handled the case at the


conclusion and upon perusal on records disclosed voluminous documents
and records in referenced to the case which undersigned needs to review
from onset of trial, as well as the heavy workload in other equally
important cases, the undersigned foresee the impossibility of filing the
same within said period;

5. In view thereof, undersigned counsel is constrained to request from this


Honorable Court an extension of ten (10) days or until 15 May 2017
within which to serve and file accused’ Memorandum;

6. The foregoing motion for extension of time is due solely to the aforesaid
reason and is not intended to delay the proceedings in this case.

PRAYER
WHEREFORE, premises considered, accused Leonardo De Leon,
Christopher De Leon and Noli Mendoza most respectfully request an extension of
ten (10) days from 05 May 2017 or until 15 May 2017 within which to file
Accused’ Memorandum.

Accused further pray for other just and equitable remedies.


Tanauan City, Batangas, 05 May 2017.

PUBLIC ATTORNEY’S OFFICE


Tanauan City District Office
Counsel for the Accused
Hall of Justice Bldg., Tanauan City

By:

HEART C. LERO
Public Attorney I
Counsel for Accused
Roll No. 61581
Lifetime IBP No. 015726
MCLE Compliance No. V-0017604; 04.15.2016

THE HON. CLERK OF COURT


RTC, Branch 83
Tanauan City, Batangas

G R E E T I N G S:

Please submit the forgoing MOTION FOR EXTENSION OF TIME TO FILE


MEMORANDUM FOR ACCUSED for the utmost consideration of the Honorable Court
immediately upon receipt hereof.

HEART C. LERO

Copy furnished:

Atty. Mariano Marcos


Private Prosecutor
Unit 103, PARC Bldg., Bru-Ger Subd.,
Pututan, Muntinlupa City

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