motex people v.reyes rev

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    REPUBLIC OF THE PHILIPPINES

    COURT OF APPEALS

    MANILA

    Fifteenth Division

    PEOPLE OF THE PHILIPPINES,

    Plaintiff-Appellee,

    -versus- C.A. G.R. CR NO. 35145RTC No. 09-270552

    GLORIA E. REYES, For: Illegal RecruitmentAccused-Appellant.

    x------------------------------------------------x

    MOTION FOR EXTENSION OF TIME

    TO FILE APPELLANTS BRIEF

    Accused-Appellant Gloria E. Reyes,1 by counsel, respectfully

    states:

    1. On 12 March 2013, she received a copy of this HonorableCourts Notice dated 22 February 2013 directing her to file her

    Appellants Brief within 30 days from receipt thereof, or until 11 April

    2013.

    2. A draft of the Appellants Brief is already being prepared.

    However, due to other urgent, equally important work of undersigned

    law intern, primarily caused by the final examinations in her academicsubjects and pressure to comply with the academic requirements, the

    undersigned law intern is constrained to request for an extension of time

    to prepare the Appellants Brief.

    3. Accused-Appellant will need an extension of 30 days from

    11 April 2013, or until 11 May 2013, to file her Appellants Brief.

    4. This motion is not interposed for delay.

    1 Hereafter referred to as the Accused-Appellant.

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    RELIEF

    WHEREFORE, Accused-Appellant respectfully prays that this

    Honorable Court grant her an extension of 30 days from 11 April 2013,

    or until 11 May 2013, to file her Appellants Brief. Other relief are alsoprayed for.

    Respectfully submitted.

    Quezon City, 8 April 2013.

    U.P. OFFICE OF LEGAL AID

    Counsel for Accused-Appellant

    Ground Floor, Malcolm HallUniversity of the PhilippinesDiliman, Quezon CityTel. No.: 9276260/Telefax: 9205514 loc. 106

    By:

    ROWENA E.V. DAROY-MORALES

    DirectorRoll of Attorneys No. 39129MCLE No. III-00723 / 16-Dec-09 / Pasig CityIBP No. LPN-04130 / Lifetime Member /Quezon CityPTR No. 7621780 / 10-Jan-13 / Quezon City

    ROBERTO N. DIO

    Supervising LawyerRoll of Attorneys No. 33736MCLE Compliance No. IV-0007432 QuezonChapterIBP No. 0070 / Lifetime Member / QuezonProvincePTR No. 3669606 / 2-Jan-13 / Makati City

    JUDITH MARIE G. BUNYI-DE LEON

    Law Intern

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    Copy furnished:

    OFFICE OF THE SOLICITOR GENERAL

    134 Amorsolo St. Legaspi Village1229 Makati City

    EXPLANATION

    The undersigned law intern respectfully manifests that copies ofthis Motion for Extension of Time to File Appellants Brief were filed withthis Honorable Court and served on the Office of the Solicitor General byregistered mail due to lack of resources to effect personal service on thisday.

    Please see attached Affidavit of Service.

    JUDITH MARIE G. BUNYI-DE LEON

    Law Intern

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