Republic of the Philippines

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE XI
Office of the Provincial Prosecutor
Province of Davao Occidental

CARLOS _________________ NPS Docket No. __________________

Complainant,

- versus - FOR: KIDNAPPING AND

FAILURE TO RETURN MINOR
AMILIA and
,
Respondents.
x--------------------------------------x

ENTRY OF APPEARANCE
WITH MOTION FOR EXTENSION OF TIME TO FILE COUNTER AFFIDAVIT

COMES NOW, the undersigned counsel unto this Honorable Office most
respectfully enters his appearance as counsel for the respondents thus request
that he be furnished copies of all orders, notices and resolutions of this case at:
____________________________

1. That on September 13, 2019, respondent received a copy of this Honorable

Office’s Subpoena. Hence, pursuant to the Subpoena, respondent has Ten (10) days
or until September 23, 2019 within which to file their counter-affidavits and other
supporting documents or affidavits of witnesses, if any;

2. On September 23, 2019, the undersigned was recently hired and engaged
as respondents’ legal representative and counsel due to financial constraints and
lack of time to gather the witnesses, specially the biological mother of
___________________ who is currently working in Kuwait as an OFW;

3. In view thereof, the undersigned will need another fifteen (15) days from
September 23, 2019 or until October 8, 2019 within which to submit Respondent's
counter-affidavit and other supporting evidence;

4. This motion is being filed due to the reason above-stated and not for the
purpose of delaying the instant case.

PRAYER

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 WHEREFORE, respondent prays that she be granted an additional Fifteen (15)
days from September 23, 2019 or until October 8, 2019 within which to submit
Respondents’ counter-affidavit and other supporting evidence.

Other substantial relief are also prayed for.

SUBMITTED, September 23, 2019, in Digos City, Davao del Sur, Philippines.

By:

___________________________
Counsel for the Respondents
Roll of Attorney’s No. _________
IBP No: ________; 11/05/18
PTR No: _________; 01/3/19
MCLE Compliance No. ___________ until 04/14/2022

With our conformity:

AMILIA EMMA

Copy Furnished:

- CARLOS _________________ – Sitio Pugad Buaya, Brgy. San Isidro, Sta. Maria, Davao
Occidental

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