Motion For Extension To File Formal Offer of Exhibits

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REPUBLIC OF THE PHILIPPINES

FIRST JUDICIAL REGION


REGIONAL TRIAL COURT
_________

THE PEOPLE OF THE


PHILIPPINES CRIM. CASE NO.0000
PLAINTIFFS, FOR: MURDER
-versus-

XXXX
ACCUSED.

X - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X

MOTION FOR EXTENSION TO FILE FORMAL OFFER OF


EXHIBITS

With utmost respect to the Honorable Court.

Accused through undersigned counsel, respectfully alleges that:

1. Today, January 21, 2019 is the deadline of the filing of Formal


Offer of Exhibit of the above entitled case;

2. However, the undersigned was only informed late that the folder
of the above entitled case was taken by the Secretary of the
Integrated Bar of the Philippines, La Union Chapter (IBP LU) for
reportorial purposes;

3. The undersigned is handling this case in de-officio under IBP


Legal Aid Program;

4. Since the folder is not ye under the possession of the undersigned,


he cannot prepare an intelligent Formal Offer of Exhibit;

5. For such reason, Accused thru the undersigned prays that he be


given sufficient time to prepare the same; and

6. This motion is not intended to delay the proceedings but solely for
the above purposes.
PRAYER
WHEREFORE, premises considered, it is respectfully prayed
from this Honorable Court that the undersigned be given sufficient
time to submit Formal Offer of Exhibits.

Other reliefs just and equitable under the premises are likewise
prayed for.

This January 21, 2019 in the City of San Fernando, La Union,


Philippines.

BY:

ATTY. BBBBB

NOTICE/COPY FURNISH

THE CLERK OF COURT


REGIONAL TRIAL COURT BRANCH 33

PROVINCIAL PROSECUTOR’S OFFICE

Greetings:

Please take notice that due to the nature of the motion, the
undersigned will submit it without further oral arguments.

Atty.BBBBBB

EXPLANATION

The foregoing motion was filed and served thru registered mail due
to distance between offices.

ATTY. BBBBB

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