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Motion Extension CA Draft

The respondent received a subpoena on February 11, 2020 requiring them to submit a counter-affidavit by February 21, 2020 in response to a case. However, the respondent only engaged counsel on February 18, 2020. Counsel requests a 15 day extension to submit the counter-affidavit due to prior professional commitments that prevent meeting the original deadline. The additional time is also needed for counsel to properly study the case, interview witnesses, and gather evidence to support the respondent's defenses.

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Stef Ocsalev
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177 views2 pages

Motion Extension CA Draft

The respondent received a subpoena on February 11, 2020 requiring them to submit a counter-affidavit by February 21, 2020 in response to a case. However, the respondent only engaged counsel on February 18, 2020. Counsel requests a 15 day extension to submit the counter-affidavit due to prior professional commitments that prevent meeting the original deadline. The additional time is also needed for counsel to properly study the case, interview witnesses, and gather evidence to support the respondent's defenses.

Uploaded by

Stef Ocsalev
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
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MOTION FOR EXTENTION OF TIME TO SUBMIT COUNTER-AFFIDAVIT

NPS DOCKET NO. XII-03-INQ-20-B-00113

Republic of the Philippines


Department of Justice
National Prosecution Service
OFFICE OF THE CITY PROSECUTOR
______________________________

______________________________ NPS DOCKET NO.


Complainant, ______________________________

-versus- -for-

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

MOTION FOR EXTENSION OF TIME


TO SUBMIT COUNTER-AFFIDAVIT

RESPONDENT, thru the undersigned counsel, and unto this


Honorable Office, most respectfully states THAT:

1. On 11 February 2020, respondent received from this


Honorable Office the Subpoena dated 10 February 2020, with
attachments, requiring him to submit a counter-affidavit and
other supporting documents in connection with the above-
cited case, within ten (10) days from receipt thereof, or until
21 February 2020;

2. Respondent engaged the services of the undersigned counsel


only on 18 February 2020;

3. Due, however, to the pressures of equally urgent professional


work and prior commitments, the undersigned counsel will not
be able to meet the said deadline;

4. Hence, respondent, through the undersigned counsel, is


constrained to request for an additional period of fifteen
(15) days from today, within which to submit the
Respondent’s Counter-Affidavit;

5. This additional time will also allow the undersigned to properly


study the case, interview the available witnesses, and gather
relevant evidence in support of respondent’s defenses;

6. The filing of this motion is done in good faith and not for
purposes of delaying the proceedings of this case but solely
due to the foregoing reasons.

Page 1 of 2
MOTION FOR EXTENTION OF TIME TO SUBMIT COUNTER-AFFIDAVIT
NPS DOCKET NO. XII-03-INQ-20-B-00113

PRAYER

WITH THE FOREGOING, it is respectfully prayed of this


Honorable Office that this Motion, praying for an EXTENSION OF
FIFTEEN (15) DAYS from today within which to submit respondent’s
Counter-Affidavit and supporting documentary evidence, BE
GRANTED.

Other just and equitable reliefs are, likewise, prayed for.

MOST RESPECTFULLY SUBMITTED this 18 February 2020


at General Santos City, Philippines.

Counsel for Respondent

Office Address:

Conforme:

Copy furnished:

Complainant

Page 2 of 2

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