1

Republic of the Philippines

REGIONAL TRIAL COURT
9th JUDICIAL REGION
BRANCH ____
Zamboanga City

_________________________ ,
Plaintiffs ,
-versus____________________________ ,
Defendants,

SPECIAL CIVIL CASE NO. _____

-FOREJECTMENT WITH PETITION FOR
ISSUANCE OF WRIT OF EXECUTION
OF DAMAGES

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

MOTION FOR EXTENSION

TO FILE MEMORANDUM OF APPEAL
COMES NOW, the undersigned counsel for Plaintiffs in the
above entitled case, and to this Honorable Office most respectfully
states:
That an Order was received by this Office dated August 19,
2015 which was issued by the Honorable Court ordering the Plaintiffs
to submit their Memorandum of Appeal within fifteen (15) days from
receipt thereof.
That Plaintiffs received the Order on September 2, 2015 which
deadline falls on September 17, 2015, within which to file their
Memorandum of Appeal.
That due to heavy work load of the counsel of the Plaintiff and
lengthy preparation of the document to be filed, the undersigned
counsel is constrained to ask before the Honorable Court for an
extension of fifteen (15) days from September 17, 2015, or until
October 2, 2015 to file to submit their Memorandum of Appeal and
other pertinent documents indispensable for this proceeding.

WHEREFORE, in view of the foregoing premises, it is most

respectfully prayed to this Honorable Court to grant the Plaintiffs an

extension of FIFTEEN (15) DAYS from September 17, 2015 or until
OCTOBER 2, 2015 within which to file and submit the MEMORANDUM OF
APPEAL and other documents..
Zamboanga City, September 11, 2015

___________________________________

Copy Furnished:

EXPLANATION
Copy of the foregoing Memorandum of Appeal for
the REGIONAL TRIAL COURT, Branch 31 was served by
registered mail, personal service thereof being
impracticable due to distance.