REPUBLIC OF THE PHILIPPINES COURT OF APPEALS MANILA

First Division PEOPLE OF THE PHILIPPINES, Plaintiff-appellee, G.R. No. 123456 - versus EDWARD CULLEN, Accused-appellant. x ------------------------------------------------------------------------------------------------------------- x MOTION FOR EXTENSION OF TIME ACCUSED-APPELLANT, by counsel, respectfully states that: 1. He has been directed to file an appellants brief by 8 February 2012. 2. The undersigned counsel, however, anticipates his inability to file the brief on or before the said due date 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 within and outside Metro Manila. For this reason, the undersigned is constrained to ask for an additional fifteen (15) days from 8 February 2012 within which to submit appellants brief. 3. This motion is not intended for delay but is motivated only by the foregoing reason. WHEREFORE, accused-appellant respectfully prays that he be granted an additional fifteen (15) days from 8 February 2012, within which to submit plaintiffs Reply. City of Manila; 7 February 2012. DE VERA GALOS LAW OFFICE 1 Espaa Boulevard, Manila By: ____________________ Counsel for the Defense Roll No. 99999 / 5-2-10 IBP. No. 88888 / 4-29-10

MCLE Compliance No. 77777 / 12-20-11 PTR No. 666666/ 01-05-10 And

____________________ Counsel for the Defense Roll No. 11111 / 5-2-10 IBP. No. 22222 / 4-29-10 MCLE Compliance No. 33333 / 12-20-11 PTR no. 44444 / 01-05-10

REQUEST FOR & NOTICE OF HEARING

THE CLERK OF COURT THE COURT OF APPEALS MANILA, FIRST DIVISION Please submit the foregoing Motion to the Court for its consideration and approval immediately upon receipt hereof and kindly include the same in the courts calendar for hearing on Friday, 10 February 2012 at 8:30 in the morning. Reparado B. Galos III 1 Espaa Boulevard City of Manila Please take notice that counsel has requested to be heard on Friday, 10 February 2012 at 8:30 in the morning.

Copy furnished through personal service: ______________________ And ______________________ Office of the City Prosecutor Manila City Hall, Manila