REPUBLIC OF THE PHILIPPINES

SUPREME COURT
Manila

MARK ELLOS y TAMAYO

Petitioner,

-versus- G.R. No. 241963

CA G.R. CR No. 40195
PEOPLE OF THE
PHILIPPINES,
Respondent.
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MOTION FOR EXTENSION OF TIME

TO FILE REPLY
(On the Respondent’s Comment on the Petition for Review on
Certiorari dated 29 October 2018)

PETITIONER, by counsel, to this Honorable Court, most

respectfully states:

1. On 29 April 2019, petitioner thru counsel, received

a copy of the respondent’s Comment (on the Petition for
Review on Certiorari) dated 3 April 2019, praying for the
denial of Petition for Review on Certiorari dated 29 October
2018 for utter lack of merit.

2. Although the undersigned counsel has started

drafting a Reply to the aforementioned respondent’s
comment, she foresees the impossibility of filing it on time
because of other voluminous and pressing workload on
equally important cases.

3. In view thereof, the undersigned counsel is

constrained to ask from this Honorable Court for an
additional period of ten days from 9 May 2019, or until 19
May 2019 within which to intelligently prepare and file said
Reply.
 4. This motion is not intended for delay but solely for
the above-stated purpose.
PRAYER

WHEREFORE, premises considered, it is most

respectfully prayed that petitioner, by counsel, be granted
an extension of ten (10) days from 9 May 2019, or until 19
May 2019 within which to intelligently prepare and file said
Reply.

Makati City for Manila, 9 May 2019.

QUIAL GINEZ BELTRAN & YU

10L, Burgundy Corporate Tower
252 Sen. Gil Puyat Avenue, 1200 Makati City
Tel. No. 8935181 / Telefax 8300712
Email @ gqrblawoffices@gqrblaw.com

By:

SANTIAGO C. QUIAL
Roll No. 40082
PTR. No. 6445201/01-15-19/Pasay City
IBP No. 059479/01-09-19/PPLM
MCLE No. VI-0016839/01-16-19/Pasig City

AILENE B. BARBARA-CAYACO
Roll No. 64298
PTR No. 7344069/01-08-19/Makati City
IBP No. 059465/01-09-19/Quezon City
MCLE No. VI-0017245/01-24-19/Pasig City

MARY JANE C. PEREZ

Roll No. 67579
PTR No. 7344067/01-08-19/Makati
IBP No. 059464/01-09-19/Makati
MCLE No. VI-0017323/01-24-19/Pasig City

JHONY MARTIN J. ALBA

 Roll No. 65770
PTR No. 7344070/01-08-19/Makati
IBP No. 059466/01-09-19/Makati
MCLE Compliance Certificate No. N/A
(Admitted to the Bar in June 2016)

Copy furnished:

COURT OF APPEALS
(CA GR CR No. 39908)
Ma. Orosa St,
Ermita, Manila
OFFICE OF THE SOLICITOR
GENERAL
134 Amorsolo Street, Legaspi
Village, 1229 Makati

REGIONAL TRIAL COURT

Branch 110, Pasay City

EXPLANATION
(Pursuant to Section 11, Rule 13
of the 1997 New Rules of Civil Procedure)

The foregoing pleading is hereby served by registered

mail, personal service not being practicable in view of the
distance and limited number of office personnel who will
carry out this mode of service.

MARY JANE C. PEREZ