BUT in ROC: 4 yrs., 2 mos., and 1D without regard to the fine, Sec.
1 of ROC
ROC-Probable Cause; 2024 DOJ-NPS- Reasonable Certainty
                                                         ????
No motion to dismiss in lieu of
Counter affidavit , Sec. 3 (c), ROC
w/n 10 days
GR: no motion to reopen PI, EXCPN: newly-discovered pieces of evidence with substance and material to the PI