Republic of the Philippines

Department of Justice
OFFICE OF THE CITY PROSECUTOR
Tabaco City

MARIBEL DE LOS SANTOS

DE LOS REYES and OFELIA
MENDOZA BAYABAN
Complainants,
NPS No. V-07-INV-18J-00280
-versus-

GERALD SERRANO
ALMONTE, ET.AL.

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

MOTION FOR EXTENSION OF TIME TO SUBMIT

COUNTER-AFFIDAVIT
The undersigned Respondent, to this Honorable Office, most
respectfully states that:

1. He received a copy of the subpoena of this Honorable Office on

November 28, 2018 and was required to submit a counter-affidavit to the
complaints stated therein within ten (10) days from receipt or until
December 8, 2018;

2. He is praying that he may be granted an additional time of ten (10)

days from the last date of submission of his counter-affidavit or until
December 18, 2018 to submit said pleading to give him time to look for a
counsel of his choice to assist him in the present case;

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

WHEREFORE, Respondent respectfully pray that he be granted an

additional ten (10) days from December 8, 2018 or until December 18, 2018
within which to submit the required counter-affidavit for the present case.
Other reliefs deemed just, proper and equitable in the premises are
likewise most respectfully prayed for.

Sto. Domingo, Albay for Tabaco City, Albay, ____________________.

By:

NOEL IMPERIAL
Respondent

NOTICE
The Clerk
Office of the Prosecutor
Province of Albay

Greetings:

Please submit the foregoing motion for consideration of the Office of the City
Prosecutor immediately upon receipt hereof without further need for oral argument.

Copy Furnished: By Registered Mail

Maribel De Los Santos De Los Reyes

P-1 Brgy. San Roque, Tabaco City

Ofelia Mendoza Bayaban

La Verde Subdivision, San Jose, Malilipot, Albay

Explanation: On account of the distance, time and personnel constraints in effecting

personal service, the Respondent is constrained to serve a copy of the foregoing motion
to the Complainants at their address above through registered mail as evidenced by
hereto attached Registry Receipt No:__________.
NOEL IMPERIAL