Republic of the Philippines

DEPARTMENT OF JUSTICE
National Prosecution Service
Office of the City Prosecutor
Butuan City

DR. ROSPT E. BRAVO NPS DOC. XIII-01-INV-20I-01991

Complainant

Versus – For:

“RIR TO DAMAGE OF PROPERTY”

CECILE PIAMONTE, ET. AL.
Respondent
/-----------------------------------------------------/

MOTION
FOR EXTENSION OF TIME
(to file counter-affidavit)
WITH ENTRY OF APPEARANCE

Respondents by undersigned counsel respectfully aver –

As per subpoena of this Honorable Office dated September 8, 2020, respondents

have until today, September 22, 2020, to submit their counter-affidavits and other
countervailing evidence;

Regrettably, it is only today that Respondent was able to secure the services of
undersigned counsel;

Respondent is constrained to ask for a 10-day extension or until October 2, 2020 to

submit the required counter-affidavits and other countervailing evidence, as undersigned
counsel needs time to prepare the affidavits of Respondents and their witnesses, whose
movements are presently restricted by reason of the COVID-19 health protocols imposed
by the Local Government of Butuan;

Hence, this instant request for extension.

This motion is interposed in the highest interest of justice and not to delay the
proceedings.

Undersigned counsel respectfully enters his appearance as counsel for respondents

and requests that all notices, pleadings and others papers be furnished to him in the
address indicated below.

WHEREFORE, it is most respectfully prayed of this Honorable Office to allow

Respondents until October 2, 2020, to submit their counter-affidavit and other
countervailing evidence and to note the appearance of undersigned counsel as counsel for
respondent.

September 22, 2020 Butuan City, Philippines.

THE LAW FIRM OF

SALISE & SULLANO
RGCS Bldg., Narra Road cor. Molave Street
8600 Butuan City
For Respondent

By:

ATTY. ROLANDO G.C. SALISE

Roll No. 48977
MCLE Compliance V-0019414 issued on April 4, 2016
IBP no. 1061873 1/3/2018
PTR No. 1446967 1/3/2018
TIN No. 908-310-719
e-mail add: boboysalise@yahoo.com
Cellphone no. 09485939047

CC:

by registry mail due to distance consideration

and lack of personnel to effect personal service-

Atty. Ron carlo I. Honculada, CPA

Coundel for complainant
Ricafort Building
JC Aquino Ave., Butuan City
Reg. mail no. __________________________