Republic of the Philippines

Third Judicial Region

REGIONAL TRIAL COURT
Branch 10
Malolos City, Bulacan

ANGELITO MENDEZ, ET AL.,

Plaintiffs,

-versus-

CIVIL CASE NO. 63-M-2001

For: Annulment of Title,
Reconveyance and Damages

Sps. BENJAMIN AND JULIE

TIRONA, ET AL.,
Defendants.
x- - - - - - - - - - - - - - - - - - - - x

SECOND MOTION FOR EXTENSION OF

TIME TO FILE MEMORANDUM
(RE: ORDER DATED 18 JUNE 2015)
PLAINTIFFS, through undersigned counsel and unto this
Honorable Court, most respectfully states that:
1.
On 10 July 2015, plaintiffs received a copy of an
Order dated 18 June 2015 issued by this Honorable Court
directing plaintiffs within thirty (30) days from notice or until 9
August 2015, to wit:

x x x plaintiffs and defendants DBP are given

thirty (30) days from notice within which to
submit their respective memorandum.
2.
Thus, plaintiffs have until 9 August 2015 within
which to file their Memorandum.
3.
Previously, Atty. Richard Neil S. Chua, the handling
counsel to this case requested for an additional period of thirty
(30) days from 09 August 2015, or up to 8 September 2015,
within which to file its Memorandum which was granted by
the Court.
4.
However, the handling counsel Atty. Richard Neil S.
Chua, went on an indefinite leave last 1 September 2015.
Thus, the foregoing case was assigned to another associate.
5.
Corollary to this, the assigned associate is not
familiar with this case and needs time to review the
voluminous files and to do the necessary legal research.
6.
In view of the foregoing, undersigned counsel
humbly requests for an additional period of thirty (30) days
from 08 September 2015, or up to 8 October 2015, within
which to file its Memorandum.
7.
This motion is being filed solely for the foregoing
reason in the interest of justice, and not for the purpose of
delay.
PRAYER
WHEREFORE, premises considered, it is respectfully
prayed of this Honorable Court that plaintiffs be granted an
additional period of thirty (30) days from 09 August 2015, or
up to 8 September 2015, within which to file its Memorandum.

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Other just and equitable reliefs are likewise prayed for.

Respectfully submitted.
Makati City for Malolos City, 08 September 2015

LIGON SOLIS MEJIA* FLORENDO

LAW FIRM
Counsel for Private Respondent
The Penthouse, ZETA Building
191 Salcedo Street, Legaspi Village
Makati City
Tel. Nos. (632) 8175672; 89406
Telefax: (632) 8945737
(*on leave)
By:

JOHN RYAN E. SEGUIT

IBP No. 0985112 / 1-8-15 / Quezon
PTR No. 0598044 / 1-8-15 / Quezon City
ROA No: 59421
MCLE Compliance No.IV-0016272/ 4-10-2013

COPY FURNISHED:
DEVELOPMENT BANK OF THE PHILIPPINES (DBP)
Legal Services Group
Counsel for Defendant DBP and Magpayo
10th Floor, DBP Building
Sen. Gil J. Puyat Avenue
Corner Makati Avenue
Makati City
ATTY. LEONARDO C. AGUILAR
Page 3 of 4

Counsel for Defendant Sps. Tirona

Heart of the City Condominium
# 210 40 Sgt. Esguerra Avenue
Quezon City

EXPLANATION
A copy of the foregoing Second Motion for Extension of
Time to file Memorandum was filed with the Honorable Court
and served to the other party by registered mail due to
distance and lack of messengerial personnel to effect personal
service.

JOHN RYAN E. SEGUIT

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