Republic of the Philippines

REGIONAL TRIAL COURT

Third Judicial Region
City of Malolos, Bulacan
Branch 11
REPUBLIC OF THE PHILIPPINES,
- versus -

Crim. Case No. 2667-M-2008

Carolina Alejo,
Accused.
x ----------------------------------------- x

2nd MOTION
FOR an EXTENSION OF TIME TO
FILE MEMORANDUM
ACCUSED, thru the undersigned counsel and unto this Honorable
Court most respectfully states that:
1. Counsel for the accused previously asked for an extension of
fifteen (15) days from November 11, 2008 to November 26,
2008 to file her Memorandum;
2.

Within this period the undersigned had already drafted the

memorandum. However, the undersigned is constraint to seek
additional period of time, for the last time, to finalize the
memorandum with the accused herself to fully present her
meritorious defense to prove her innocence;

3.

The failure to submit the required memorandum is likewise

attributable to the number of paperwork and the demand of
equally significant legal obligations, not to mention other
professional commitments;

4. This motion is not being made to delay the proceeding of this

case but solely for the purpose aforementioned.
WHEREFORE, premises considered, it is most respectfully prayed of
this Honorable Court that accused be given an additional period of ten (10)
days from today or until December 6, 2008, within which to file her
memorandum.
Other reliefs just and equitable are likewise prayed for.
RESPECTFULLY SUBMITTED.
Malolos City, Bulacan.
November 26, 2008.

CHRISTIAN PETER C. BAUTISTA

For the Defendant
2ND Floor, Essen Bldg,
Paseo de Congreso
IBP No. 744240
PTR NO.0035986/18-01-2008
Roll No. 54119
Malolos City, Bulacan
MCLE NOT YET REQUIRED
NOTICE
The Branch Clerk
Regional Trial Court, Branch 11
Malolos City, Bulacan

Fiscal Michael Dayao

Public Prosecutor
Office of the Provincial Prosecutor
Malolos City, Bulacan
Greetings:
Please take notice that the undersigned shall submit the foregoing motion for
the kind consideration and approval of this Honorable Court sans oral argument.
CHRISTIAN PETER C. BAUTISTA
COPY FURNISHED:

Fiscal Michael Dayao

Public Prosecutor
Office of the Provincial Prosecutor
Malolos City, Bulacan
Ramon Guevarra, Jr.
# 167-C Paco, Obando,
Bulacan
EXPLANATION
In compliance with Section 11, Rule 13 of the 1997 Rules of Civil Procedure, it is
respectfully manifested that service through registered mail of the foregoing pleading was
resorted to, due to limited personnel to effect personal service.

CHRISTIAN PETER C. BAUTISTA