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The motion requests a 10-day extension, until June 26, to file a counter-affidavit and a 15-day extension, until July 1, to waive the provisions of Article 125 of the Revised Penal Code. It states that the respondent recently engaged the services of the undersigned counsel and more time is needed to study the case and confer with witnesses. The motion is submitted without need for oral argument.
The motion requests a 10-day extension, until June 26, to file a counter-affidavit and a 15-day extension, until July 1, to waive the provisions of Article 125 of the Revised Penal Code. It states that the respondent recently engaged the services of the undersigned counsel and more time is needed to study the case and confer with witnesses. The motion is submitted without need for oral argument.
The motion requests a 10-day extension, until June 26, to file a counter-affidavit and a 15-day extension, until July 1, to waive the provisions of Article 125 of the Revised Penal Code. It states that the respondent recently engaged the services of the undersigned counsel and more time is needed to study the case and confer with witnesses. The motion is submitted without need for oral argument.
Department of Justice NATIONAL PROSECUTION SERVICE Office of the City Prosecutor Zamboanga City MOTION FOR EXTENSION OF TIME TO FILE COUNTER AFFIDAVIT RE: NPS DOCKET NO.IX-06-INQ-16F-00474 X------------------------------------------------------------------------x EX-PARTE MOTION FOR EXTENSION OF TIME TO FILE COUNTER-AFFIDAVIT WITH WAIVER COMES NOW, Respondent DEXTER PIOQUINTO y JALA through undersigned counsel and unto this Honorable Office, most respectfully states that: 1. The Subpoena of the Honorable Office dated 8 June 2016 was duly received by Respondent on the same day, requiring him to file and submit his Counter-Affidavit within ten (10) days from receipt thereof, thus he has until 18 June 2016 within which to file and submit the same; 2. However, considering that Respondent has just recently engaged the services of the undersigned counsel today and that counsel needs more time to study the case, and to confer with him and his witnesses in preparing an intelligible defense in their counter-affidavits. The undersigned anticipates that he will not be able to file the CounterAffidavit of Respondent within the period provided. Thus, he is constrained to ask for an extension of TEN (10) days from 16 June 2016 or until 26 June 2016 within which to file and submit his Counter-Affidavit. Respondent likewise requests for extension of Waiver of the provisions of Article 125 of the Revised Penal Code for FIFTEEN (15) days from 16 June 2016 or until 01 July 2016; 3. Undersigned Counsel most respectfully manifests sincerity in the relief prayed for herein and that the same is not in any way intended to delay the proceedings hereof. PRAYE R
WHEREFORE, it is most respectfully prayed of this Honorable
Office that Respondent be given an additional period of TEN (10) days from 16 June 2016 or until 26 June 2016 within which to file and submit his Counter-Affidavit. Respondent likewise requests for extension of Waiver of the provisions of Article 125 of the Revised Penal Code for FIFTEEN (15) days from 26 June 2016 or until 01 July 2016. Other reliefs as may be just and equitable under the premises are likewise prayed for. City of Zamboanga, Philippines, 16 June 2016. The Receiving Clerk Office of the City Prosecutor Hall of Justice, Sta. Barbara Zamboanga City Greetings! Please take notice that the undersigned counsel is submitting the foregoing Ex-Parte Motion for Extension of Time to file CounterAffidavit with Waiver for the consideration and approval of this Honorable Office without need of oral argument.