REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

7TH Judicial Region
Branch __,
____________, Cebu

PEOPLE OF THE PHILIPPINES,

Plaintiff,

CRIM. CASE NO. TCR-2018-1234

and 1235
-versus- FOR: Violation of Sections 5 and
11, Art. II, R.A. 9165
__________________________,
Accused.
X-------------------------/

MOTION FOR EXTENSION OF TIME TO FILE MEMORANDUM

IN SUPPORT OF PETITION FOR BAIL

Accused, through the undersigned counsel, unto this Honorable

Court, most respectfully alleges THAT:

1. On May 10, 2018, the undersigned counsel made his cross-

examination on the prosecution’s lone witness for purposes of
accused’s Petition for Bail. The Counsel for the State conducted his
redirect examination and the undersigned counsel thereafter posed
questions for his re-cross examination.

2. In an Order made in open court, both parties were given

ten (10) days within which to file their respective memoranda with
respect to the Petition for Bail and subsequent thereto, the petition
shall have been deemed to be submitted for resolution. Hence, the
defense has until today, May 21, 2018, to file its memorandum in
support of accused’s Petition for Bail.

3. However, the transcript of stenographic notes of the

above-mentioned hearing, on which the bulk and substance of
accused’s memorandum shall be based, has yet to be completed.
 4. Considering the foregoing, the undersigned counsel
cannot submit the memorandum on the due date, which is today, and
is constrained to ask for an additional period of ten (10) days to give
ample time for the completion of the transcript of stenographic notes
as well as the preparation and filing of the memorandum.

5. This motion is being filed due to the reason above-stated

and not for the purpose of causing delay to the instant case.

PRAYER

WHEREFORE, it is most respectfully prayed of this Honorable

Court that the defense be granted an additional ten (10) days from
today, May 21, 2018, or until May 31, 2018 within which to file a
Memorandum in support of accused’s petition for bail.

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

RESPECTFULLY SUBMITTED.

May 21, 2018, _________________, Philippines

ABCD LAW OFFICES

Counsel for Accused
Room ____, 4th Floor, Toire Building,
___________ Avenue, ____ Cebu City
Tel. No. _______________ / __________________________

By:

JUANITO DUTERTE
Roll No. 12345
PTR No. 123456; 1-3-18; C.C.
IBP No. AR000123; 1-3-18; C.C.
MCLE Compliance, (Admitted to the Bar on 6-17-18)