MOTION FOR EXTENTION OF TIME TO SUBMIT COUNTER-AFFIDAVIT

NPS DOCKET NO. XII-03-INQ-20-B-00113

Republic of the Philippines

Department of Justice
National Prosecution Service
OFFICE OF THE CITY PROSECUTOR
______________________________

______________________________ NPS DOCKET NO.

Complainant, ______________________________

-versus- -for-

______________________________ ______________________________
Respondent.
x---------------------------------------------------x

MOTION FOR EXTENSION OF TIME

TO SUBMIT COUNTER-AFFIDAVIT

RESPONDENT, thru the undersigned counsel, and unto this

Honorable Office, most respectfully states THAT:

1. On 11 February 2020, respondent received from this

Honorable Office the Subpoena dated 10 February 2020, with
attachments, requiring him to submit a counter-affidavit and
other supporting documents in connection with the above-
cited case, within ten (10) days from receipt thereof, or until
21 February 2020;

2. Respondent engaged the services of the undersigned counsel

only on 18 February 2020;

3. Due, however, to the pressures of equally urgent professional

work and prior commitments, the undersigned counsel will not
be able to meet the said deadline;

4. Hence, respondent, through the undersigned counsel, is

constrained to request for an additional period of fifteen
(15) days from today, within which to submit the
Respondent’s Counter-Affidavit;

5. This additional time will also allow the undersigned to properly

study the case, interview the available witnesses, and gather
relevant evidence in support of respondent’s defenses;

6. The filing of this motion is done in good faith and not for
purposes of delaying the proceedings of this case but solely
due to the foregoing reasons.

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 MOTION FOR EXTENTION OF TIME TO SUBMIT COUNTER-AFFIDAVIT
NPS DOCKET NO. XII-03-INQ-20-B-00113

PRAYER

WITH THE FOREGOING, it is respectfully prayed of this

Honorable Office that this Motion, praying for an EXTENSION OF
FIFTEEN (15) DAYS from today within which to submit respondent’s
Counter-Affidavit and supporting documentary evidence, BE
GRANTED.

Other just and equitable reliefs are, likewise, prayed for.

MOST RESPECTFULLY SUBMITTED this 18 February 2020

at General Santos City, Philippines.

Counsel for Respondent

Office Address:

Conforme:

Copy furnished:

Complainant

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