Motion For Extension of Time

 

Republic of the Philippines DEPARTMENT OF JUSTICE National Prosecution Service OFFICE OF THE PROVINCIAL PROSECUTOR Ilagan, Isabela

HANNAH ANGELA T. ASUNCION

NPS DOCKRT NO. II-04-INV-191-00899

Complainant, -versus-

for

ROBILITA B. RESPICIO 

Respondent.

VIOLATION OF R.A. 7610 (CHILD ABUSE)

x--------------------------x-------------------------------------------------------------x --------x

MOTION FOR EXTENSION OF TIME

Respondent, by the undersigned counsel, and unto this Honorable Office of the City Prosecutor, most respectfully states that:  1. Respondent engaged the services of undersigned counsel only on October 23, 2019;  2. Respondent received the subpoena on October 07, 2019 and thus has until file an extension to extend until October 26, 2019  within which to submit his counter-affidavit;  3. However, due to the pressures of equally urgent professional work and prior commitments, the undersigned counsel will not be able to meet the said deadline; 4. As such, undersigned counsel is constrained to request for an additional period of ten (10) day from today within which to submit Respondent's counter-affidavit and other supporting evidence. Moreover, this additional time will also allow the undersigned to interview the available witness and study this case;   5. This Motion is not intended for delay but solely due to the foregoing reasons.   P R A Y E R  

WHEREFORE, Respondent most respectfully prays of this Honorable City Prosecutor of Ilagan, Isabela that he be given an additional period of ten (10) day  from today within which to submit his counter-affidavit counter-affid avit and other documentary evidence. 

 

 

MOST RESPECTFULLY SUBMITTED. 

Other relief just and equitable are likewise prayed for.  Philippines, es, October 25, 2019. Diffun, Quirino, Philippin

ATTY. MA KAREN A. BALDONADO-GUILLERMO Counsel of the Respondent Copy Furnished by Registered Mail to:

HANNAH ANGELA T. ASUNCION Complainant Magsaysay, Cordon, Isabela

OFFICE OF THE PROVINCIAL PROSECUTOR Province of Isabela Ilagan City, Isabela

REQUEST:

The Clerk of the Provincial Prosecutor Justice Hall, Ilagan, Isabela Greetings: Immediately upon receipt hereof, kindly submit the foregoing Motion to the Honorable Provincial Prosecutor for his consideration, approval and resolution, with or without complainant’s comment/opposition comment/op position thereto.

ATTY. MA KAREN A. BALDONADO-GUILLERMO Counsel of the Respondent EXPLANATION

Copies of the foregoing Motion for Extension of Time to File Counter-Affidavit were served on the Complainant and Office of the Provincial Provinci al Prosecutor, Ilagan City, Isabela by registered mail since personal service is not practicable in view of time constraint and the distance between the residence of the petitioner and the Office of the Affiants.

ATTY. MA KAREN A. BALDONADO-GUILLERMO Counsel of the Respondent