REPUBLIC OF THE PHILIPPINES

COURT OF APPEALS
MANILA

GIRLY GIRON-CHAVEZ,
Petitioner,
C.A. G.R. No. 38438
-versus- (Crim. Case No. 156507)
For: Slight Physical Injuries
PEOPLE OF THE
PHILIPPINES
and ESPERANZA A.
DOMDOM,

Respondents-Appellees.

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MOTION FOR EXTENSION OF TIME TO

MEMORANDUM OF APPEAL

Respondent, ESPERANZA A. DOMDOM, by counsel, unto this

Honorable Court, respectfully states:

1. On 26 January 2017, herein Respondent received a Notice

to Memorandum of Appeal.

2. Per the Honorable Courts Notice dated 13 January 2017,

appellee has fifteen (15) days from receipt of the Notice to
file Memorandum of Appeal or until 10 February 2017.

3. However, due to the heavy volume of work consisting of

drafting of equally urgent pleadings, court appearances,
client conferences and other similar works, coupled with
the busy schedule involving personal and family
commitments, the undersigned counsel needs more time
to prepare Memorandum for herein appellee.

4. Hence the undersigned counsel is constrained to move for

an additional period of fifteen (15) days from 09 February
2017 or until 24 February 2017 within which to file the
Memorandum.

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 5. This motion is interposed solely for the aforementioned
reason and is not intended to delay the proceedings in this
case.

PRAYER

WHEREFORE, premises considered, it is most respectfully

prayed of this Honorable Court that Respondent, ESPERANZA A.
DOMDOM be granted an extension of fifteen (15) days from today,
or until 24 February 2017, within which to file his Appellants
Brief.

Other reliefs, just and equitable, are likewise prayed for.

Marikina City for Manila City. 09 February 2017.

LORENZO MARVIN S. REYES

Counsel for the Respondent
27, Pikador Street, Midtown Subdivision
San Roque, Marikina
Roll of Attorneys No. 66539
IBP Roll No. 1071676; February 2, 2017; RSM
PTR No. 2692851 - Pasig; 01-27-2017
MCLE (exempted) Admitted to the Bar : 2016

Copy Furnished:

COURT OF APPEALS
CA Building, M. Orosa Street
Ermita, Manila

BRANCH CLERK OF COURT

Regional Trial Court Branch 167
Pasig City

OFFICE OF THE CITY PROSECUTOR

Hall of Justice
Pasig City

GIRLY GIRON-CHAVEZ
Petitioner
No. 12 Rome St. Ciudad Grande, Pasig City

FORTUN AND SANTOS LAW OFFICES

Counsel for the Petitioner

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134 CRM Avenue, BF Homes Almanza
Las Pinas City 1750

OFFICE OF THE SOLICITOR GENERAL

134 Amorsolo St., Legaspi Village
Makati City

EXPLANATION

Copies of the foregoing Motion for Extension were filed and

served on the above-named parties through registered mail for lack of
material time and extreme urgency for the timely filing and service of
the same.

LORENZO MARVIN S. REYES