Republic of the Philippines

DEPARTMENT OF JUSTICE
National Prosecution Service
OFFICE OF THE PROVINCIAL PROSECUTOR
Ilagan, Isabela

VIVIAN PON Y DAQUINOTAS,

Complainant,

-versus- NPS DOCKET NO. INQ-19D-00251

For: Physical Abuse under RA 9262

KEVIN RAY HAVERS,

Respondent.

x------------------------------------------x

MOTION FOR EXTENSION OF TIME

TO FILE COUNTER-AFFIDAVIT

The respondent, KEVIN RAY HAVERS, unto this Honorable City Prosecutor, most
respectfully prays that he be granted an extension of fifteen (15) days from July 11, 2010, his last
day to file his counter-affidavit and those of his witnesses having received the subpoena together
with a copy of the Complaint-Affidavit on July 1, 2010 on the ground that he is still looking for a
counsel of his own choice to assist him in the above-entitled case.

1. Respondent was arrested and detained in the Dumaguete City Police Station

from April 26, 2019 until April 29, 2019. On April 29, 2019, respondent received a

subpoena from the Prosecutor’s Office charging him of the above-stated offense and

requiring him to submit his counter-affidavit and other supporting documents within (ten)10

days from receipt thereof;

2. Today, , appears to be the last day for the submission of

respondent(s’) counter-affidavit and other supporting documents;

3. There is a need to further study the case and to gather relevant evidence to

support the defense/s of the Respondent(s), thus, this request for a period of ten (10) day

extension within which to submit the respondent(s’) Counter-Affidavit and other supporting

documents;
 4. That the filing of this motion is done in good faith and not for purposes of delaying

the proceedings of this case but for the reason above-stated.

 PRAYER

WHEREFORE, premises considered, it is respectfully prayed of the Honorable

Prosecutor that this Motion, praying for an extension of TEN (10) DAYS within which to

submit Respondent’s Counter-Affidavit and supporting documents, be granted.

 (date)
, at the City/Municipality/Province of , Philippines.

PUBLIC ATTORNEY’S OFFICE

Department of Justice
DISTRICT OFFICE

By:

ATTY.
Public Attorney
Roll No.
IBP No.
MCLE Comp. No. III-

CONFORME:

(respondent)

NOTICE
 The Clerk
Office of the
City/Municipality/
Provincial
Prosecutor/City/Munici
pality/ Province of

GREETINGS:

Please submit the foregoing motion for the consideration of the

Honorable City Prosecutor immediately upon receipt hereof without further
oral argument.

ATTY.

Copy furnished:

(Complainant / counsel for the complainant)

This motion is not intended to delay the proceedings of the case.

Dumaguete City, Philippines, this 2nd day of May 2019.

KEVIN RAY HAVERS

Hermogina Apartments,
Calindagan, Dumaguete City

SUBSCRIBED AND SWORN to before me, a Notary Public in and for

______________________________, this _____ day of _____________, 2010,
at _______________________. Affiant exhibited to me his
_______________________________. I further certify that I personally
examined the affiant and I am satisfied that he understood it and that he
voluntarily executed the same.

Doc. No. _____;

Page No. _____;
Book No. _____;
Series of 2019.

Copy Furnished by
Registered Mail to:

CORNELIO CHITO M. DELA PEÑA

OIC- Chiel, Legal Divison
Revenue District office
Ilagan, Isabela

JOCELYN LORA
Revenue District Office No. 15
Ilagan, Isabela

LORNA B. BINARAO
Revenue District Office No. 15
Ilagan, Isabela

REQUEST:

The Clerk of the Provincial Prosecutor

Justice Hall, Ilagan, Isabela

Greetings:
Immediately upon receipt hereof, kindly submit the foregoing Motion to the
Honorable Provincial Prosecutor for his consideration, approval and resolution,
with or without complainant’s comment/opposition thereto.

BERNARD Q. LIM
Respondent

EXPLANATION

Copies of the foregoing Motion for Extension of Time to File Counter-

Affidavit were served on the Affiants and the OIC-Chief of Legal Division of
Revenue District Office, Ilagan, Isabela by registered mail since personal service
is not practicable in view of time constraint and the distance between the
residence of the petitioner and the Office of the Affiants.

BERNARD Q. LIM
Respondent