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Motion For Extension of Time

The document is a motion filed by respondent's counsel requesting a 10-day extension to submit a counter-affidavit. The respondent only engaged counsel on March 2nd, with the current deadline being March 4th. However, due to other professional commitments, counsel will not be able to meet the deadline. As such, the motion requests an additional 10 days, until March 14th, to allow counsel time to interview witnesses and properly study the case. Granting the extension will not cause delay but is necessary due to the stated reasons.

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Martin Martel
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2K views2 pages

Motion For Extension of Time

The document is a motion filed by respondent's counsel requesting a 10-day extension to submit a counter-affidavit. The respondent only engaged counsel on March 2nd, with the current deadline being March 4th. However, due to other professional commitments, counsel will not be able to meet the deadline. As such, the motion requests an additional 10 days, until March 14th, to allow counsel time to interview witnesses and properly study the case. Granting the extension will not cause delay but is necessary due to the stated reasons.

Uploaded by

Martin Martel
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd

Republic of the Philippines

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE XI
Office of the City Prosecutor
City of Davao

EVELYN T. ALBUT NPS Docket No. _______________


Plaintiff,

- versus - FOR:

HILARIO M. TAMBY,
Accused.
x--------------------------------------x

MOTION FOR EXTENSION OF TIME TO FILE


COUNTER AFFIDAVIT

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


March 2, 2018;

2. Respondent received the subpoena on February 22, 2018 and thus has
until March 4, 2018within 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) days from March 4, 2018 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.

PRAYER

WHEREFORE, Respondent most respectfully prays of this Honorable


City Prosecutor that he be given an additional period of Ten (10) days
from March 4, 2018 within which to submit his counter-affidavit and other
documentary evidence.

Page 1 of 2
MOST RESPECTFULLY SUBMITTED.

Other relief just and equitable are likewise prayed for.

Digos City, Davao del Sur, Philippines, March 2, 2018.

By:

ATTY. _________________________
Counsel for the Respondent
Roll of Attorney’s No. ________
IBP Number: __________ ; 01/04/18
PTR Number: __________ ; 01/03/18
MCLE Compliance No.: (NEW LAWYER) / May ____, 2____

Copy Furnished:

Page 2 of 2

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