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    (1) Plaintiff Fernando A. San Agustin filed a motion for extension of time to submit a reply to Defendant Manny L. Otto's answer in Civil Case No. 920813. (2) Plaintiff's counsel requests an additional 15 days, from the due date of January 10, 2013, to submit the reply due to the pressure of other urgent legal work. (3) The motion is submitted to the court on January 3, 2013 and notice is provided to the defendant and clerk of court.

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    Motion to Dismiss-with Desistance

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    (1) Plaintiff Fernando A. San Agustin filed a motion for extension of time to submit a reply to Defendant Manny L. Otto's answer in Civil Case No. 920813. (2) Plaintiff's counsel requests an additional 15 days, from the due date of January 10, 2013, to submit the reply due to the pressure of other urgent legal work. (3) The motion is submitted to the court on January 3, 2013 and notice is provided to the defendant and clerk of court.

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    123 views4 pages

    Motion To Dismiss-With Desistance

    Uploaded by

    Anonymous
    (1) Plaintiff Fernando A. San Agustin filed a motion for extension of time to submit a reply to Defendant Manny L. Otto's answer in Civil Case No. 920813. (2) Plaintiff's counsel requests an additional 15 days, from the due date of January 10, 2013, to submit the reply due to the pressure of other urgent legal work. (3) The motion is submitted to the court on January 3, 2013 and notice is provided to the defendant and clerk of court.

    Copyright:

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    of 4

    Republic of the Philippines

    FIRST JUDICIAL REGION


    REGIONAL TRIAL COURT
    Branch 39, Quezon City

    FERNANDO A. SAN AGUSTIN,


    Plaintiff,
    Civil Case No.: 920813
    -versus-
    For: DAMAGES
    MANNY L. OTTO,
    Defendant.
    x---------------------------------x

    MOTION FOR EXTENSION OF TIME

    PLAINTIFF, by counsel, respectfully states that:


    (1) He has been required to file a Reply to defendant’s Answer by 10 January 2013;
    (2) The undersigned counsel, however, anticipates his inability to file the Reply on or before
    said due date because of the tremendous pressure of other equally urgent professional
    work requiring the preparation of pleadings and almost daily trial appearances before the
    various courts within and outside Metro Manila. For this reason, the undersigned is
    constrained to ask for an additional fifteen (15) days from 10 May 2013 within which to
    submit the plaintiff’s Reply;
    (3) This motion is not intended for delay but is motivated only by the foregoing reason.

    WHEREFORE, plaintiff respectfully prays that he be granted additional fifteen (15)


    days from 10 January 2013, or until 25 Jnauary 2013, within which to submit plaintiff’s Reply.

    Quezon City, Philippines; 27 December 2012.

    ATTY. GELIE ERIKA P. ESTEBAN


    Counsel for the Plaintiff
    3F La Azotea Bldg., Session Road, Baguio City
    PTR No. 99909; 01/04/2012; Baguio City
    IBP OR No: 6928764; 01/04/2012; Baguio City
    Roll No.: 81319; 04/08/2005
    Baguio City, Philippines
    TIN No. 143-444-434-000
    NOTICE AND REQUEST

    THE CLERK OF COURT


    RTC Branch 39, Quezon City

    ATTY. REY M. ABANADOR


    ABANADOR-LIM LAW OFFFICE
    Qeuzon City, Philippines

    Greetings!

    Please note that on 3 January 2013, at 8:30 o’clock in the morning or as soon as the
    undersigned counsel may be heard, he will submit the foregoing motion for the consideration and
    approval of the Honorable Court.

    ATTY. GELIE ERIKA P. ESTEBAN

    Copy Furnished:

    ATTY. REY M. ABANADOR


    ABANADOR-LIM LAW OFFFICE
    Qeuzon City, Philippines

    Pg136
    REPUBLIC OF THE PHILIPPINES
    Fourth Judicial Region
    MUNICIPAL TRIAL COURT
    ROSARIO, BATANGAS

    THE PEOPLE OF THE PHILIPPINES,


    Complainant. CRIM. CASE NO. 5761

    -versus- For: Violation of B.P. 22

    CARIDAD YUSON,
    Accused.

    MOTION TO DISMISS

    COMES NOW the undersigned Private Complainant, to this Honorable


    Court, most respectfully moves for the dismissal of the Complaint for lack of cause
    of action on the ground that the filing of the instant case only arose out of
    misunderstanding between the parties and that the accused did not commit the
    offense charge.

    PRAYER

    WHEREFORE, it is respectfully prayed that the Complaint be dismissed for


    lack of cause of action and by virtue of an Affidavit of Desistance duly executed
    by the undersigned.
    Other reliefs just and equitable are likewise prayed for.

    Rosario, Batangas. February ___, 2018.

    RANDY P. BANDOJO
    Private Complainant
    JURAT

    REPUBLIC OF THE PHILIPPINES)


    CITY OF LIPA ) S.S.

    VERIFICATION

    I, PSINSP DANILO PASIA COMIA, of legal age, Filipino, married, and a


    resident of Brgy. Balagtasin II, San Jose, Batangas, after having been sworn to in
    accordance with law, do hereby depose and say that:

    I am the respondent in the above-entitled case and I have caused the


    preparation and filing of this position paper;

    I have read and understood the contents of this position paper and that all the
    matter stated therein are true and correct of my own personal knowledge.

    IN WITNESS WHEREOF, I have hereunto set my hand this


    ___________________ in the City of Lipa, Province of Batangas, Philippines.

    PSINSP DANILO PASIA COMIA


    Affiant

    SUBSCRIBED AND SWORN to before me this __________________, in


    the City of Lipa, Province of Batangas, Philippines. Affiant exhibited to me his
    ________________________.

    Doc. No.
    Page No.
    Book No.
    Series of 2018

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