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Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES


12th Judicial Region
Marawi City, Lanao del Sur

PEOPLE OF THE PHILIPPINES


Plaintiff,
CRIM. CASE no.: 0078-2021

FOR: Malicious Mischief


-versus-

H. NAIM AMEROL COSAIN


Accused
x-------------------------------------x

MOTION FOR EXTENSION OF TIME


TO FILE DEMURRER TO EVIDENCE

Accused, through the undersigned counsel, unto this Honorable Court


most respectfully states that:

1. The Prosecution rest his case after the presentation of his last witness
and the formal offer of his evidence on 15 September 2022 at 8:30 in
the morning;

2. Accused’s counsel desires to file a demurrer to evidence on the


ground that upon the facts and the law, the plaintiff has shown no
right to relief or the evidence presented were insufficient. However,
Transcript of Stenographic Notes (TSN) were not yet given to the
undersigned.

3. Thus, the undersigned counsel is constrained to humbly ask this


Honorable Court for the extension of time to file a demurrer to
evidence with a period of five (5) days from the date of reception of
the evidence offered by the Prosecution.

4. Based on the foregoing reasons, there is no intention to delay the


disposition of the case and thus, the said counsel humbly pleas for
leniency in the interest of substantial justice and equity.

RELIEF

WHEREFORE, premises considered, it is respectfully prayed to this


Honorable Court that an extension of five (5) days, from the date of
reception of prosecution’s evidence, to file a demurrer to evidence.

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Other reliefs deem just and equitable are likewise prayed for.
Respectfully submitted this ___________ of ___________, 2022

FOR THE PLAINTIFF AS PRIVATE PROSECUTOR

ATTY. ALYASSAR SAUDI S. SULOG


Roll no. 60400 (Mar 2012)
IBP Lifetime Member No. 013760
PTR OR No. 0447468 (01/03/2022)
MCLE Compliance No. (VII): 0015473 (04-14-2025)
Mobile no: 09454654671
Email: attysausulog@gmail.com

NOTICE OF HEARING

The Branch Clerk of Court


Municipal Trial Court in Cities
Marawi City

GREETINGS:

Please submit the foregoing motion for the consideration and approval
of the Honorable Court immediately upon receipt hereof.

Alyassar Saudi S. Sulog

Copy furnished:

Pros. Ibrahim Mimbalawag


Office of the City Prosecutor,
Marawi City

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