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2nd Motion For Add Time

The respondent is requesting an additional 10 days to file a counter-affidavit in response to a complaint. She was previously granted an extension until February 26th but requires more time due to the distant location of witnesses, the need for further study of the case, and her lawyer's busy schedule with court appearances and other cases. She asserts this second request is made in good faith and not to delay the case. The motion asks the court to grant an extension until March 8th to file the counter-affidavit.

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Mikko Acuba
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44 views3 pages

2nd Motion For Add Time

The respondent is requesting an additional 10 days to file a counter-affidavit in response to a complaint. She was previously granted an extension until February 26th but requires more time due to the distant location of witnesses, the need for further study of the case, and her lawyer's busy schedule with court appearances and other cases. She asserts this second request is made in good faith and not to delay the case. The motion asks the court to grant an extension until March 8th to file the counter-affidavit.

Uploaded by

Mikko Acuba
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOC, PDF, TXT or read online on Scribd
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Republic of the Philippines

Department of Justice
NATIONAL PROSECUTION SERVICE
OFFICE OF THE PROVINCIAL PROSECUTOR
Province of Samar
Catbalogan City

THE PEOPLE OF THE PHILIPPINES NPS DOCKET NO. V111-


09-
INV-19A1-00901

-versus-
FOR:
VIOL. OF SEC.4 (4) UNDER
CYBERCRIME PREVENTION
ACT OF 2012 (RA NO.
10175) IN REL TO ART 355
OF THE RPC

MARY LUNA V. MIRANDA


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

SECOND MOTION FOR ADDITIONAL TIME

COMES NOW respondent by counsel and unto the Honorable Office


respectfully states that:

1. On 04 February 2019, respondent received the subpoena dated


01 February 2019 directing the respondent to submit within ten (10) days
from receipt thereof her counter-affidavit to the complaint and with the
given period, respondent had until 14 February 2019 to comply therewith;

2. On 13 February 2019, the respondent filed a motion for


additional time in which the respondent prayed to be given an additional
time of ten (10) days thereof or until 26 February 2019 to file the said
counter-affidavit;

3. However, considering that the offense charged requires an


intelligent preparation and a serious study of the case, the distant location
and time availability of the respondent’s witnesses, the herein respondent
failed to finish the said counter-affidavit within the said extended period;

4. Again, her counsel, whom she just engaged last 08 February


2019 is presently laden with professional chores consisting of almost
daily-court appearances and preparation of equally-important pleadings,
apart from the need to intelligently study the case, that he needs a non-
extendible period within which to file the desired pleadings;

5. The motion is made in good faith and never intended to delay the
disposition of this case, but solely due to valid reasons herein set forth.

WHEREFORE, premises considered, it is respectfully prayed of the


Honorable Office that herein respondent be given an additional period of
ten (10) days from 26 February 2019 or until 08 March 2019 to file said
counter-affidavit to the said complaint.

Catbalogan City, 26 February 2019.

ACUBA AND ACUBA LAW OFFICES


Counsel for Respondent
196 G/F Laohoo Bldg., San Bartolome St.
Brgy. 3, Catbalogan City, Samar

By:

DEMETRIO MEDINO J. ACUBA


Ground Floor, Laohoo Bldg.
196 San Bartolome St.
Brgy. 3, Catbalogan City, Samar
IBP No. 0039892, May 08, 2018
PTR No. 5694043, 6. 19.2018 Catbalogan City
Roll of Attorneys No.71321
MCLE Exempt

REQUEST

OFFICE OF THE PROVINCIAL PROSECUTOR


Hall of Justice
Catbalogan City
GREETINGS:

Immediately upon receipt hereof, kindly submit the foregoing


“Second Motion for Additional Time” to the Honorable Office for its
appropriate consideration.

ATTY. DEMETRIO MEDINO J. ACUBA

Cc: (By Registered Mail due to Distance)

MARY JOY NAVARRO DALUMPINES


Purok 4, Brgy. Maulong,
Catbalogan City, Samar

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