Download as doc, pdf, or txt
Download as doc, pdf, or txt
You are on page 1of 6

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE PROVINCIAL PROSECUTOR OF NUEVA ECIJA
HALL OF JUSTICE
CABANATUAN CITY

MELVIN DOBLA NAVA,


Complainant,

-versus- I.S. NO. 06I-3222

FRANCISCO S. SAMSON,
Respondent.
x - - - - - - - - - - - - - - - - - - - - - - --X
ALEX CRUZ CRUDA,
Complainant, I.S. NO. 06I-3253

-versus-

FRANCISCO S. SAMSON,
Respondent.
x-------------------------------------------x
SUSAN F. CUA,,
Complainant, I.S. NO. 06H-2961

-versus-

FRANCISCO S. SAMSON,
Respondent.
x-----------------------------------------x
LYDIA DELA CRUZ MUYOT,
Complainant, I.S. NO. 06I-3165

-versus-

FRANCISCO S. SAMSON, ET.AL.


Respondents.
x-------------------------------------------x
RJAY A. BUSTAMANTE,
Complainant, I.S. NO. 06I-3166

-versus-

FRANCISCO S. SAMSON, ET.AL.


Respondents.
x-----------------------------------------x

URGENT MOTION FOR EXTENSION OF TIME


TO FILE COUNTER-AFFIDAVIT

COMES NOW the undersigned respondent in the above-entitled case and


unto this Honorable Office respectfully move for an extension of time of at least
ten (10) days from today within which to submit his counter-affidavits and
affidavits of his witnesses in the above entitled case, considering that he has not
yet secured the services of a counsel who will assist him in the preparation of his
counter-affidavits.
PREMISES CONSIDERED, and in the interest of justice, it is
respectfully prayed that respondent herein be given a period of 10 days from
today within which to submit his counter affidavits.
Such other reliefs and remedies just and equitable in the premises are
likewise prayed for.

Gapan City for Cabanatuan City, December 14, 2006

FRANCISCO S. SAMSOM
Respondent

The Officer-in-Charge
Office of the Provincial Prosecutor
For the Province of Nueva Ecija
Hall of Justice, Cabanatuan City

Greetings:

Immediately upon receipt hereof, kindly submit the foregoing motion to


the Honorable Office for its kind consideration and approval.

FRANCISCO S. SAMSON
Respondent
Copy furnished by registered mail:

Melvin Dobla Nava


Baluga, Talavera, N.E.

Alex Cruz Cruda


Poblacion, San Isidro, NE

Susan F. Cua
Magpapalayok, San Leonardo, NE

Lydia dela Cruz Muyot


Brgy. Pulo, San Isidro, NE

Rjay Atazar Bustamante


Sto. Cristo, San Isidro, NE.
RESPONDENTS, through the undersigned counsel and unto this
Honorable Office respectfully alleges:

That considering that the above-entitled case was referred to the


undersigned only this morning and in order for the undersigned to
familiarize himself with the facts of the case, to give the undersigned
sufficient time to prepare and study the above-entitled cases and to
interview his witnesses, it is respectfully prayed that he be given an
extension of time of at least fifteen (15) days from today within which to
submit respondent’s counter-affidavit and affidavit of his witnesses in the
above entitled cases;

Since herein respondent is represented by the Public Attorney’s


Office, it is likewise prayed that he be exempted from the payment of
filing fees and be considered as an indigent litigant;

The above motion is not intended to delay the early termination of


these cases;

PREMISES CONSIDERED, and in the interest of justice, it is


respectfully prayed that herein respondent be given a period of 15 days
from today within which to submit his counter affidavit and that of his
witnesses.

Such other reliefs and remedies just and equitable in the premises
are likewise prayed for.

September 8, 2006, Gapan City for Cabanatuan City,

PUBLIC ATTORNEY’S OFFICE


Gapan City District Office
2nd Floor, 4J Bldg., Bucana, Gapan City
Counsel for the respondent

By:

JULIUS CAESAR A. MUSTARD


Public Attorney II

The Officer-in-Charge
Office of the Provincial Prosecutor
For the Province of Nueva Ecija
Hall of Justice, Cabanatuan City

Greetings:

Immediately upon receipt hereof, kindly submit the foregoing motion


to the Honorable Office for its kind consideration and approval.

JULIUS CAESAR A. MUSTARD


Copy furnished:

Fernando Vidon
Nick Alfanta
Caridad G. Solitario
Complainants
All of Brgy. Maugat,
San Antonio, N.E.

CERTIFICATION

Due to distance and lack of messengerial personnel, a copy of this


pleading was served to complainants thru registered mail with return card.

J.C. A. MUSTARD

REPUBLIC OF THE PHILIPPINES


DEPARTMENT OF JUSTICE
OFFICE OF THE PROVINCIAL PROSECUTOR OF NUEVA ECIJA
HALL OF JUSTICE
CABANATUAN CITY

ROBERTO DELA CRUZ, ET.AL.,


Complainants
-versus- I.S. NO. 04L-4923-24

PRIMO ADVINCULA, JR. ET.AL., F O R : MURDER & PHYSICAL


Respondents, INJURIES
X----------------------x

URGENT MOTION FOR EXTENSION OF TIME


TO FILE COUNTER-AFFIDAVIT

COME NOW the undersigned respondents in the above-entitled case and


unto this Honorable Office respectfully move for an extension of time of at least
ten (10) days from today within which to submit their respective counter-
affidavits and affidavits of their witnesses in the above entitled case, considering
that they have not yet secured the services of counsel who will assist them in the
preparation of their counter-affidavits.

PREMISES CONSIDERED, and in the interest of justice, it is


respectfully prayed that respondents herein be given a period of 10 days from
today within which to submit their counter affidavits.
Such other reliefs and remedies just and equitable in the premises are
likewise prayed for.

Gapan City for Cabanatuan City, February 10, 2005

PRIMO ADVINCULA, JR. EDGAR ADVINCULA


Respondent Respondent

AMANG ADVINCULA
Respondent

The Officer-in-Charge
Office of the Provincial Prosecutor
For the Province of Nueva Ecija
Hall of Justice
Cabanatuan City

Greetings:

Immediately upon receipt hereof, kindly submit the foregoing motion to


the Honorable Office for its kind consideration and approval.
PRIMO ADVINCULA, JR. EDGAR ADVINCULA
Respondent Respondent

AMANG ADVINCULA
Respondent

You might also like