Republic of the Philippines

DEPARTMENT OF JUSTICE
National Prosecutor Service
OFFICE OF THE PROVINCIAL PROSECUTOR
Province of Cagayan

MARIVIC TAQUIGA,
Complainant,

-versus- NPS DOCKET NO. II-02-INV-19A-00020

For: “FRUSTRATED MURDER”
ROMEL REYES et. al,
Respondents.
x--------------------------------------------------x

ENTRY OF APPEARANCE
WITH MOTION FOR EXTENSION OF TIME TO FILE COUNTER
AFFIDAVIT

Respondent, ROMEL REYES and DINO REYES, through the

undersigned counsel, respectfully states:

The undersigned law firm enters its appearance as counsel or any

of its counsels for the respondents. Henceforth, it is most respectfully
prayed that all pleadings, notices, orders, resolutions and other
processes of the Honorable Office in connection with the above-
captioned case be directed to the following address:

CUMIGAD LAW OFFICES

10-A Arellano Street, J&C Lasam-Villrose Bldg.,
Tuguegarao City

Conforme:

ROMEL REYES

DINO REYES

On the Motion for Extension of Time to Counter Affidavit:

1. Respondents, Romel Reyes and Dino Reyes, received a copy

of the Subpoena dated 12 February 2019 February 2019 issued under
the authority of APA Maria Paula Gaspar.
 2. In the Subpoena, Respondents was ordered to submit their
Counter-Affidavit within fifteen (15) days from their receipt of the same.

3. It is most respectfully manifested that herein respondents

only secured the services of the undersigned law office only on 25
February 2019.

4. Due to the gravity of the offense and complexity of the case,

it is most respectfully prayed that, the undersigned be given an
extension of fifteen (15) days from 26 February 2019 or until 12 March
2019 within which to file the Counter-Affidavits for both respondents.

5. This motion is not intended to delay the proceedings but is

prompted solely by the above-stated reason.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed

that respondents be given an extension of fifteen (15) days or until 12
March 2019 within which to file their Counter-Affidavit.

Such other reliefs deemed just and equitable under the premises
are likewise prayed for.

Respectfully submitted.

26 February 2019.

Tuguegarao City.

CUMIGAD LAW OFFICES

10-A Arellano Street, J&C Lasam-Villrose Bldg.,
Tuguegarao City

By:
ROTCIV R. REYES
Roll No. 68067
IBP No. (Or pending)
PTR No. 2509938/02-04-2019/Tuguegarao City
MCLE Exempt

EXPLANATION
 Due to the distance between the office of the undersigned
counsel and the counsels for the other parties and the dearth of a
messenger, personal service of this Entry of Appearance with Motion for
Extension of Time to File Answer is impracticable, hence, service is made
through registered mail.

MARY GRACE V. PULIDO SADIAN

Copy furnished:

MARIA PAULA D. GASPAR

Office of the Regional Prosecutor
M&M Building, Pengue Ruyu
Tuguegarao City, Cagayan

MARIVIC TAQUIGA
Complainant
Lannig Solana Cagayan