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.
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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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