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    Motion For Extension of Time-Sta - Ana

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    Leo Archival Imperial
    This document is a motion filed by private respondents requesting a 10-day extension to submit a position paper and draft decision in response to an order from the provincial office of the Department of Agrarian Reform in Camarines Sur. It cites the volume of work and other professional commitments of counsel that prevent submission within the original 10-day deadline. The motion prays that an extension until May 26, 2019 be granted to submit the required documents. It includes an affidavit of service for the motion by registered mail.

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    Motion For Extension of Time-Sta - Ana

    Uploaded by

    Leo Archival Imperial
    162 views5 pages
    This document is a motion filed by private respondents requesting a 10-day extension to submit a position paper and draft decision in response to an order from the provincial office of the Department of Agrarian Reform in Camarines Sur. It cites the volume of work and other professional commitments of counsel that prevent submission within the original 10-day deadline. The motion prays that an extension until May 26, 2019 be granted to submit the required documents. It includes an affidavit of service for the motion by registered mail.

    Original Title

    MOTION FOR EXTENSION OF TIME-STA.ANA

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    This document is a motion filed by private respondents requesting a 10-day extension to submit a position paper and draft decision in response to an order from the provincial office of the Department of Agrarian Reform in Camarines Sur. It cites the volume of work and other professional commitments of counsel that prevent submission within the original 10-day deadline. The motion prays that an extension until May 26, 2019 be granted to submit the required documents. It includes an affidavit of service for the motion by registered mail.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    162 views5 pages

    Motion For Extension of Time-Sta - Ana

    Uploaded by

    Leo Archival Imperial
    This document is a motion filed by private respondents requesting a 10-day extension to submit a position paper and draft decision in response to an order from the provincial office of the Department of Agrarian Reform in Camarines Sur. It cites the volume of work and other professional commitments of counsel that prevent submission within the original 10-day deadline. The motion prays that an extension until May 26, 2019 be granted to submit the required documents. It includes an affidavit of service for the motion by registered mail.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 5

    Republic of the Philippines

    DEPARTMENT OF AGRARIAN REFORM


    PROVINCIAL OFFICE-CAMARINES SUR
    Doña Dolores Bldg., Roxas Avenue
    Diversion Road, Triangulo
    Naga City, Camarines Sur

    IN RE: PETITION FOR


    CANCELLATION OF CLOA NO.
    00124402, OCT NO. 3653, IN THE NAME
    OF LEONOR B. STA. ANA, ET.AL DUE
    TO ERRONEOUS IDENTIFICATION APO NO. __________
    OF FARMER-BENEFICIARY.

    SULPICIO L. PAVIO (FABEYO), MA.


    GRACE E. CELZO, RONA F. FELICITAS
    & NEMIA F. IBAY,
    Petitioners,

    -versus-

    LEONOR B. STA. ANA, DENNIS


    JUNNEL STA. ANA, SHIELA DARILAY
    AND MA. PERLA CELESTE,
    Private Respondents.

    DAR PROVINCIAL OFFICE OF


    CAMARINES SUR II,
    Represented by Provincial Agrarian
    Reform Officer II
    Public Respondent.
    and

    ATTY. VICTORIANO D. CAUBANG II,


    in his capacity as the REGISTER OF
    DEEDS OF CAMARINES SUR,

    Nominal Public Party


    Respondent

    x--------------------------------------x
    MOTION FOR EXTENSION OF TIME TO FILE POSITION
    PAPER AND DRAFT DECISION
    Private Respondents, represented by Dennis Junnel B. Sta. Ana, by
    counsel, to this Honorable Office, most respectfully state that:

    1. The undersigned counsel, received a copy of the Order of this


    Honorable Office dated March 12, 2019 on May 6, 2019 directing the
    Respondents, to submit a Position Paper together with the draft decision
    within ten (10) days from receipt or until May 16, 2019;

    2. However, due to the volume and pressure of work, coupled with


    other equally important and urgent professional commitments, the
    undersigned counsel cannot submit the required documents within the
    period required and will need an additional ten (10) days from May 16,
    2019 or until May 26, 2019 within which to submit the same;
    3. This motion is being filed due to the reason above-stated and not for
    the purpose of delaying the instant case.

    PRAYER

    WHEREFORE, Private Respondents, through counsel, respectfully


    pray that they be granted an additional ten (10) days from May 16, 2019 or
    until May 26, 2019 within which to submit the required Position Paper and
    draft decision.

    Other reliefs deemed just, proper and equitable in the premises are
    likewise most respectfully prayed for.

    Naga City for Philippines, May 16, 2018.

    By:

    LEO ARCHIVAL I. IMPERIAL


    Counsel for the Plaintiffs
    Unit 2D, Prifel Bldg. J. Miranda Ave., Naga City
    ROLL NO. 60619-March 23, 2012
    IBP No. 0294- CY-2019
    PTR No. 0418426- January 7, 2019
    MCLE Compliance No. VI-0003390, October 12, 2017
    Tel No: 472-82-61/C.P. No: 09175126032

    Copy Furnished: By Registered Mail

    ATTY. RODEL ABOGADO


    Counsel for Petitioners
    Public Attorney’s Office
    Naga City, Camarines Sur

    Explanation: On account of the distance, time and personnel constraints in effecting


    personal service, counsel for the Private Respondents is constrained to serve a copy of
    the foregoing motion to the counsel of the Petitioners at his address above through
    registered mail as evidenced by hereto attached Registry Receipt No:__________.

    ATTY. LEO ARCHIVAL I. IMPERIAL


    REPUBLIC OF THE PHILIPPINES)
    Province of ____________________) S.S.
    City/Municipality of _____________)
    x-----------------------x

    AFFIDAVIT OF SERVICE

    I, ATTY. LEO ARCHIVAL I. IMPERIAL, of legal age, married, and with office
    address at Unit 2-D, Prifel Bldg., J. Miranda Ave., Naga City, Camarines Sur, after
    having been duly sworn in accordance with law, hereby depose and say:
    1. That in my aforementioned capacity, I had served a copy of the “MOTION FOR
    EXTENSION OF TIME TO FILE COMMENT ON THE PETITION FOR REVIEW” in
    the case entitled "JESUS PESIMO, JR., ET. AL. VS. HEIRS OF SALVACION
    VALER, ETC..," docketed as CA G.R. SP. NO. 156924 by registered mail to the
    office of Atty. Jamara Leigh C. Fernandez and Atty. Regine Joy l. Magabo, with
    office address at DOJ Public Attorney’s Office (Special and Appealed Cases
    Service) 5/F DOJ Agencies Bldg. NIA Road cor. East Ave., Diliman, 1104, Quezon
    City;

    2. That I also served a copy of said pleading with the Court of Appeals with address
    at Ma. Orosa St., Manila by registered mail; and

    3. That service was made by registered mail on account of the distance, time and
    personnel constraints in effecting personal service.

    IN WITNESS WHEREOF, I have hereunto set my hand this _____________ at


    _____________, Philippines.

    ATTY. LEO ARCHIVAL I. IMPERIAL


    Affiant
    UMID CRN-0111-0898561-5

    SUBSCRIBED AND SWORN to before me, this _____________, by the Affiant


    whom I have identified through his competent evidence of identity as indicated above
    and.

    NOTARY PUBLIC

    Doc. No. ______;


    Page No. ______;
    Book No.______;
    Series of 20____.

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