Republic of the Philippines

Department of Justice
NATIONAL PROSECUTION SERVICE
OFFICE OF THE PROVINCIAL PROSECUTOR
________

_____________________________

,
Complainants,

- versus - NPSD NO.

For:

,
Respondents.
x--------------------------x

FORMAL ENTRY OF APPEARANCE OF COUNSEL

WITH MOTION TO RE-OPEN
PRELIMINARY INVESTIGATION

The ____________, through the undersigned counsels, most

respectfully enters its appearance as counsel for respondent
________________. Henceforth, it is respectfully requested that the counsel be
furnished with copies of all notices, resolutions, pleadings and other
processes at its address herein-below indicated.

Respondent _____________, through counsel, respectfully states that:

1. Respondent is presently in _______________;

2. Respondent was informed by her relatives in __________ that

on _______________, a copy of the Subpoena in this instant case addressed to
her was served at the said address.

3. In the Subpoena, respondent was directed to submit her

counter-affidavit and other supporting documents or affidavits of her
witness/es on ___________ and _____________ both at 1:30 o’ clock in the
afternoon.
 4. Hence, respondent humbly moves that the preliminary
investigation be re-opened and she be given at least _____________ days
within which to submit her counter-affidavit and countervailing evidence
considering that she is in ____________ and needs time to leave from work
and subscribe the same before the ___________ which is distant from her
place.

RELIEF

WHEREFORE, respondent _____________ respectfully prays that:

a. the appearance of her counsel be duly noted; and

b. the preliminary investigation be re-opened and

she be given at least __________ days within which to submit
her counter-affidavit and countervailing evidence.

Respondent likewise prays for such other reliefs that are just and
equitable under the premises.

By:

NOTICE

The Receiving Officer:

Please submit the foregoing motion for the kind consideration and
approval of the Honorable Investigating Prosecutor immediately upon
receipt hereof.

Copy furnished: